Section 212.3

Table of Contents

Subsection 212.3(1) - Foreign affiliate dumping — conditions for application

Commentary

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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

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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)

Subparagraph 212.3(1)(a)(ii)

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Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper

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Paragraph 212.3(1)(b)

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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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Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper

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Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper

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Subsection 212.3(1.1)

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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(2) - Foreign affiliate dumping — consequences

Commentary

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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 815
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 224
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) pro-rata highly dilutive stock dividend 115

28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3

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2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR

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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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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

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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 306
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation proportionate distribution by LLP treated as dividend 126
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 108

23 May 2013 IFA Round Table, Q. 6(h)

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Articles

Subsection 212.3(4) - Qualifying substitute corporation

Cross-Border Class

Commentary

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Dividend Time

Qualifying Substitute Corporation

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Subsection 212.3(5) - Modification of terms — paragraph (10)(e)

Commentary

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Subsection 212.3(6)

Subsection 212.3(7) - Reduction of deemed dividend

Commentary

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Administrative Policy

12 June 2015 External T.I. 2015-0583821E5 - 212.3(7)(d) - Prescribed information

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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.

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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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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

Commentary

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Subsection 212.3(9) - Paid-up capital reinstatement

Commentary

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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 307

23 May 2013 IFA Round Table, Q. 6(b)

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23 May 2013 IFA Round Table Q. 6(g)

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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.

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Steve Suarez, "An Analysis of Canada's Latest International Tax Proposals", Tax Notes International, September 29, 2014, p. 1131.

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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

Henry Chong, "Section 212.3: Missing PUC Adjustments", Canadian Tax Highlights, Vol. 21, No. 5, May 2013, p. 12.

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Paragraph 212.3(9)(b)

Articles

Subparagraph 212.3(9)(b)(ii)

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 248 - Subsection 248(1) - Corporation proportionate distribution by LLP treated as dividend 126
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 108
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 230

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 168
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 332

Subsection 212.3(10) - Investment in subject corporation

Paragraph 212.3(10)(a)

Commentary

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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) 97
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) no transfer of property on deemed s. 111(4)(e) acquisition 147

Paragraph 212.3(10)(b)

Commentary

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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 244

Paragraph 212.3(10)(c)

Commentary

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Administrative Policy

23 May 2013 IFA Round Table Q. 6(f)

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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)

Commentary

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Paragraph 212.3(10)(e)

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Paragraph 212.3(10)(f)

Commentary

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Administrative Policy

23 May 2013 IFA Round Table Q. 6(a)

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Articles

Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", draft 2014 Annual CTF Coference Report paper.

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Paragraph 212.3(10)(g)

Commentary

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Subsection 212.3(11) - Pertinent loan or indebtedness

Commentary

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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 232

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

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Subsection 212.3(16) - Exception — more closely connected business activities

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Paragraph 212.3(16)(a)

Commentary

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Administrative Policy

6 September 2013 External T.I. 2013-0474671E5 - "more closely connected business activities"

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23 May 2013 IFA Round Table Q. 6(d)

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Paragraph 212.3(16)(b)

Commentary

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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)

Commentary

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Subsection 212.3(17) - Dual officers

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Subsection 212.3(18) - Exception — corporate reorganizations

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Paragraph 212.3(18)(a)

Commentary

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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) 97
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) no transfer of property on deemed s. 111(4)(e) acquisition 147

Articles

Finance

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Subparagraph 212.3(18)(a)(i)

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Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper

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Subparagraph 212.3(18)(a)(ii)

Clause 212.3(18)(a)(ii)(B)

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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(18)(b)

Commentary

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Paragraph 212.3(18)(c)

Commentary

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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 26
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 911

Articles

Subparagraph 212.3(18)(c)(ii)

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 599
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 332

Paragraph 212.3(18)(d)

Commentary

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Subsection 212.3(18.1)

Subsection 212.3(19) - Preferred shares

Commentary

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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

Commentary

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Subsection 212.3(21) - Persons deemed not to be related

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Subsection 212.3(22) - Mergers

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Subsection 212.3(23) - Indirect investment

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Subsection 212.3(24) - Indirect funding

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Subsection 212.3(25) - Partnerships

Paragraph 212.3(25)(a)

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Paragraph 212.3(25)(b)

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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 361

Articles

Paragraph 212.3(25)(c)

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Paragraph 212.3(25)(d)

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Paragraph 212.3(25)(e)

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Paragraph 212.3(25)(f)

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Subsection 212.3(26)