Section 260

Subsection 260(1) - Definitions

Securities Lending Arrangement

See Also

Barnes v. Revenue and Customs Commissioners, [2014] BTC 5, [2014] EWCA Civ 31

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Words and Phrases
requirement

Newton v. Commissioner of Taxation of the Commonwealth of Australia, [1958] A.C. 450 (PC)

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 51

Administrative Policy

5 June 2001 Internal T.I. 2000-0053047 - REVERSE REPURCHASE TRANSACTION

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26 November 1996 External T.I. 9638145 - SECURITIES LENDING

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18 November 1996 External T.I. 9637095 - sla

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23 April 1992 Memorandum 921211 (September 1992 Access Letter, p. 39)

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Articles

William W. Chip, "Are Repos Really Loans?", Tax Notes International, 27 May 2002, p. 1011.

Brown, "How to Spot the Difference Between Repos and Stock Loans", International Financial Law Review, June 1996, p. 51.

Subsection 260(2) - Non-disposition

Administrative Policy

2019 Ruling 2018-0776381R3 - Part XIII tax under a reverse repo agreement

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) the negative repo spread on a reverse repo was not interest 231

24 April 1995 External T.I. 9427715 - SECURITIES LENDING

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Articles

Morrow, "Repo, Reverse Repo and Securities Lending Markets in Canada", Bank of Canada Review, Winter 1994-1995, p. 61.

Barnes, Spector, "Cross-Border Securities Lending Payments: Income and Search of a Character", [Tax Management International], p. 295

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Malach, "Securities Lending and Dividend Rental Arrangements and Preferred Share Financing - An Update", Tax Profile, October 1990, p. 33.

Hayos, "Security Lending and Dividend Rentals: What They Are and the Tax Implications", 1989 Conference Report, c. 25.

Subsection 260(8) - Non-resident withholding tax

Administrative Policy

2002 Ruling 2002-0152203 - SECURITIES LENDING ARRANGEMENT

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9 June 1994 TI HCW 1083-6

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4 August 1999 External T.I. 9908885 - TOTAL RETURN SWAPS

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24 April 1995 External T.I. 9427715 - SECURITIES LENDING

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Articles

Philip D. Morrison, "Stock Lending Transactions and U.S. Withholding Tax", Tax Management International Journal, Vol. 42, No. 6, June 14, 2013, p. 361

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Subsection 260(11) - Corporate members of partnerships

Paragraph 260(11)(c)

Administrative Policy

24 March 2014 External T.I. 2013-0495461E5 - Paragraph 260(11)(c) of the Income Tax Act

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