Section 76.1

Subsection 76.1(1) - Non-resident moving debt from Canadian business

Administrative Policy

16 September 2011 Internal T.I. 2010-0383571I7 - Transfer of Property to a US Head Office

s. 76.1 would not apply to a "loan" between the US head office of a US corporation and its Canadian branch that is now being closed down, as such...

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Orest Moysey, Stan Mag, "New Canadian Branch Making Rules for Foreign Banks: Opportunities and Issues", International Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 6, p. 1869.