Subsection 212.3(1) - Foreign affiliate dumping — conditions for application
Articles
Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42
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Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Sabrina Wong, "Summary of International Amendments in Bill C-63, Budget Implementation Act, 2017, No. 2", International Tax (Wolters Kluwer CCH), No. 97, December 2017, p. 6
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Paragraph 212.3(1)(a)
Paragraph 212.3(1)(b)
Articles
Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee
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Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Subsection 212.3(1.1)
Articles
Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Subsection 212.3(2) - Foreign affiliate dumping — consequences
Commentary
Administrative Policy
2015 Ruling 2015-0604051R3 - Internal Reorganization
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(iii) | note resulting from share redemption required to be vapourized on amalgamation/GAAR assessment required to reduce outside Canadian basis that US parents “paid for” by paying 5% Canadian withholding tax/rep re pubco share value being unaffected | 899 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.11) | s. 55(3)(a) rulings conditional on U.S. parents accepting GAAR assessments to reduce their outside basis | 230 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) | pro-rata highly dilutive stock dividend | 117 |
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(10) - Paragraph 212.3(10)(a) | deemed investment under s. 111(4)(e) | 109 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(a) | deemed investment under s. 111(4)(e) | 109 |
2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 17 - Subsection 17(2) | 571 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share | MRPS were shares | 147 |
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
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Ian Crosbie, "Recent Transactions of Interest, Part I", 2015 CTF Annual Conference paper
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.3) - Subparagraph 88(1)(c.3)(i) | 141 |
Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Subsection 212.3(3) - Dividend substitution election
Commentary
Administrative Policy
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) - Paragraph 212.3(9)(b) - Subparagraph 212.3(9)(b)(ii) | s. 212.3(9)(b)(ii) PUC restoration for upper-tier QSCs on the payment by a U.S. LLP of a proportionate “dividend” to lower tier CRIC partners | 349 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | proportionate distribution by LLP treated as dividend | 128 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | proportionate LLP distribution to three direct or indirect general or limited partners treated as dividend on single class of shares | 110 |
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Subsection 212.3(4) - Qualifying substitute corporation
Cross-Border Class
Dividend Time
Commentary
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Qualifying Substitute Corporation
Subsection 212.3(5) - Modification of terms — paragraph (10)(e)
Subsection 212.3(6)
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Subsection 212.3(7) - Reduction of deemed dividend
Commentary
Administrative Policy
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
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Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Paul Barnicke, Nelson Ong, "FA Dumping: PUC Offset", Canadian Tax Highlights, Volume 22, Number 10, October 2014, p. 5.
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Charles Taylor, "Foreign Affiliate Dumping Developments", International Tax, No. 72, October 2013, p. 9
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) | 143 |
Subsection 212.3(8) - Paid-up capital adjustment
Subsection 212.3(9) - Paid-up capital reinstatement
Commentary
Administrative Policy
22 May 2014 IFA Roundtable Q. 1, 2014-0526691C6 - IFA 2014 - CRIC Guarantees of debt for no fee
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(10) - Paragraph 212.3(10)(b) | imputed benefit from no-fee guarantee | 355 |
23 May 2013 IFA Round Table, Q. 6(b)
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Angelo Nikolakakis, "Foreign Affiliate Dumping – The New Paid-Up Capital Offset and Reinstatement Rules", International Tax (Wolters Kluwer CCH), October 2014 Number 78, p.1.
Steve Suarez, "An Analysis of Canada's Latest International Tax Proposals", Tax Notes International, September 29, 2014, p. 1131.
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(c) | 257 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(e) | 193 |
Paul Stepak, Eric C. Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60
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Steve Suarez, "Canada's 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers", Tax Notes International, December 9, 2013, p. 935
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Charles Taylor, "Foreign Affiliate Dumping Developments", International Tax, No. 72, October 2013, p. 9
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(7) | 142 |
Paragraph 212.3(9)(b)
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
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Subparagraph 212.3(9)(b)(ii)
Administrative Policy
15 September 2020 IFA Roundtable, Q.6
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | circular transactions to effect a s. 212.3(9)(b)(ii) PUC reinstatement abused that provision | 172 |
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | proportionate distribution by LLP treated as dividend | 128 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | proportionate LLP distribution to three direct or indirect general or limited partners treated as dividend on single class of shares | 110 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(3) | two Canadian corporate partners immediately beneath the U.S. border are QSCs respecting investments made by lower-tier CRICs in a U.S. LLP | 238 |
Variable A
Clause (b)
Administrative Policy
2016 Ruling 2016-0629011R3 - PUC reinstatement under 212.3(9)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(c) - Subparagraph 212.3(18)(c)(v) | exclusion where (10)(f) corp on-subscribes proceeds in FA investments | 176 |
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(5) - Paragraph 261(5)(a) | cross-border PUC of both lower- and upper-tier CRICs computed both in Cdn$ and U.S.$ where lower-tier CRIC had U.S.$ EFC | 348 |
Subsection 212.3(10) - Investment in subject corporation
Paragraph 212.3(10)(a)
Commentary
Administrative Policy
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(a) | deemed investment under s. 111(4)(e) | 109 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) | no transfer of property on deemed s. 111(4)(e) acquisition | 155 |
Paragraph 212.3(10)(b)
Commentary
Administrative Policy
22 May 2014 IFA Roundtable Q. 1, 2014-0526691C6 - IFA 2014 - CRIC Guarantees of debt for no fee
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) | reinstatement under s. 212.3(9)(c)(ii)(A)(II) through PUC distributions of dividends | 276 |
Paragraph 212.3(10)(c)
Commentary
Administrative Policy
Articles
John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33
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Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Paragraph 212.3(10)(d)
Paragraph 212.3(10)(e)
Commentary
Articles
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Paragraph 212.3(10)(f)
Commentary
Administrative Policy
Articles
Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42
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Paragraph 212.3(10)(g)
Subsection 212.3(11) - Pertinent loan or indebtedness
Commentary
Administrative Policy
23 May 2013 IFA Round Table Q. 6(c)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11) | blanket PLOI election | 86 |
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Subsection 212.3(13)
Administrative Policy
26 May 2016 IFA Roundtable Q. 11, 2016-0642031C6 - PLOI late-filed penalties
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.13) | potential administrative relief on computing late-filed PLOI election penalties on a debit-by-debit basis | 244 |
Subsection 212.3(14) - Rules for paragraph (10)(f)
Paragraph 212.3(14)(a)
Articles
Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Subsection 212.3(15) - Control
Commentary
Articles
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Subsection 212.3(16) - Exception — more closely connected business activities
Articles
Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42
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Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee
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Paragraph 212.3(16)(a)
Commentary
Administrative Policy
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Paragraph 212.3(16)(b)
Commentary
Articles
Tim Barrett, Andrew Morreale, "Foreign Affiliate Update", 2019 Conference Report (Canadian Tax Foundation), 35: 1 – 53
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Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Paragraph 212.3(16)(c)
Subsection 212.3(17) - Dual officers
Subsection 212.3(18) - Exception — corporate reorganizations
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
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Paragraph 212.3(18)(a)
Commentary
Administrative Policy
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(10) - Paragraph 212.3(10)(a) | deemed investment under s. 111(4)(e) | 109 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) | no transfer of property on deemed s. 111(4)(e) acquisition | 155 |
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Finance
Subparagraph 212.3(18)(a)(i)
Subparagraph 212.3(18)(a)(ii)
Clause 212.3(18)(a)(ii)(B)
Articles
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Paragraph 212.3(18)(b)
Paragraph 212.3(18)(c)
Commentary
Administrative Policy
2012 Ruling 2012-0451421R3 - Purchase of Target and bump
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.3) - Subparagraph 88(1)(c.3)(i) | guarantee | 32 |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(4) - Paragraph 88(4)(b) | Target Amalco 2 formed post-AOC and pre-bump (occurring on amalgamation of Target Amalco 2 with Bidco) is a continuation its predecessors for s. 88(1)(c) midamble purposes/prepackaging transactions before formation of Target Amalco 2/Target asset buyers agree not to purchase Target shares | 995 |
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Subparagraph 212.3(18)(c)(ii)
Articles
Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee
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Subparagraph 212.3(18)(c)(v)
Administrative Policy
2016 Ruling 2016-0629011R3 - PUC reinstatement under 212.3(9)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) - Paragraph 212.3(9)(b) - Subparagraph 212.3(9)(b)(ii) - Variable A - Clause (b) | PUC restoration where borrowed money dividended up only to the level of a lower-tier CRIC, with cross-border PUC of both lower- and upper-tier CRICs computed both in Cdn$ and U.S.$ where lower-tier CRIC had U.S.$ EFC | 651 |
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(5) - Paragraph 261(5)(a) | cross-border PUC of both lower- and upper-tier CRICs computed both in Cdn$ and U.S.$ where lower-tier CRIC had U.S.$ EFC | 348 |
Paragraph 212.3(18)(d)
Subsection 212.3(18.1)
Commentary
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Subsection 212.3(19) - Preferred shares
Commentary
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
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Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49
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Subsection 212.3(20) - Assumption of debt on liquidation or distribution
Subsection 212.3(21) - Persons deemed not to be related
Subsection 212.3(22) - Mergers
Subsection 212.3(23) - Indirect investment
Subsection 212.3(24) - Indirect funding
Subsection 212.3(25) - Partnerships
Paragraph 212.3(25)(a)
Paragraph 212.3(25)(b)
Commentary
Administrative Policy
2013 Ruling 2013-0491061R3 - Upstream Loans
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a) | yo-yo transaction: US Salesco is repaid upstream loan by Can Opco 1, and then relends to Can Opco 1 when no longer a parent | 419 |
Articles
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66.
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Paragraph 212.3(25)(c)
Paragraph 212.3(25)(d)
Paragraph 212.3(25)(e)
Paragraph 212.3(25)(f)
Subsection 212.3(26)
Articles
Henry Shew, "Foreign Affiliate Dumping and Estates with Non-Resident Beneficiaries", Canadian Tax Focus, Vol. 10, No. 1, February 2020, p.9
Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee
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Paragraph 212.3(26)(b)
Articles
Tim Barrett, Andrew Morreale, "Foreign Affiliate Update", 2019 Conference Report (Canadian Tax Foundation), 35: 1 – 53
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Commentary