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Edward A. Heakes, "The Proposed Revisions to Back-to-Back Loan Rules", International Tax Planning (Federated Press), Vol. XIX, No. 4, 2014, p. 1357. -- summary under Paragraph 212(3.1)(e)

For example, in situations where there is a U.S. parent and there are secured loans to both the parent and the Canadian subsidiary, it is often the case that, because of U.S. tax considerations, the Canadian assets are provided as security for the Canadian obligation but not as security for the U.S. obligation. ...

Ilana Ludwin, "Application of the Transactional Profit Split Method in Canada", Tax Management International Journal, 2015, p. 98. -- summary under Subsection 247(2)

OECD Model, Art. 9 accommodation of considering overall commercial relations (p.101) As with the American provision, Article 9 does not require consideration of particular transactions but rather the overall commercial or financial relations between two enterprises. ...

Ken S. Skingle, V. Daniel Jankovic, "Can a Partner Enter into a Contract with a Partnership of Which the Partner Is a Member?", Tax for the Owner-Manager, Volume 13, Number 4, October 2013, p. 8 -- summary under Subsection 96(1.1)

Crawford, "Funding of Retired Partners' Cash Requirements", 1992 Conference Report, C. 34 Crawford, "Tax and Capital Considerations in Refunding Retired Partners' Income and other Cash Requirements", 1991 Conference Report, c. 34. ...

Carrie Smit, "Debt Restructuring and the Falling Canadian Dollar" -- summary under Paragraph 80(2)(k)

Example of separate s. 80(2)(k) forgiven amount and s. 39(2) FX gain (pp. 5-6) [A]ssume that the Canadian debtor described above is now settling and extinguishing the US$100 million debt for cash consideration of US$15 million (or CDN$21.43 million). ...

Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper -- summary under Subsection 15(2.6)

As a result of the significant appreciation in the value of the US dollar…the repayment of the loan in cash by Forco would result in a capital gain in the hands of Canco under 39(1).... 1) Cansub assumes the loan as consideration for a cash payment by Forco equal to the amount outstanding under the loan. ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under unattached

These fees could be viewed as a return of consideration paid by the PBC to the UWs and could fall within regulation 6202.1(1)(c). ...

Peter Neelands, Suzy Lendvay, "Valuation of IP based on a royalty stream", The Lawyer's Daily (LexisNexis Canada), January 24, 2018 -- summary under Other

Although this may serve as a useful starting point to begin consideration of the value of IP, courts have been reluctant to accept this methodology. ...

Kyle B. Lamothe, Alexander Demner, "Section 212.1 Post Mortem Pipeline Comfort Letter", Tax for the Owner-Manager, Vol. 20, No. 2, April 2020, p. 8 -- summary under Subsection 212.1(6)

Alternate transactions for life interest trusts (pp. 8-9) … Assume that the LIT transfers its shares of Opco for Holdco shares alone (that is, without receiving any non-share consideration). ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27 -- summary under Subsection 219.1(1)

However, if the “amount” of the corporation’s debt obligation is equal to the principal amount of the debt ($100), it appears that the corporation could avoid departure tax for which it otherwise might be liable if the trading discount on the debt payable were taken into consideration, even though the net FMV of the debts receivable and payable, considered in isolation, is nil. ...

M. Elena Hoffstein, Corina S. Weigl, "Overview of the Twenty One Year Rule—A Trust Lawyer's Perspective", 2014 Ontario Tax Conference (Canadian Tax Foundation) -- summary under Subsection 104(6)

This method, however, is hampered by significant practical considerations. ...

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