Section 90

Subsection 90(1) - Dividend from non-resident corporation

See Also

Ahmad v. The Queen, 2013 DTC 1112 [at 601], 2013 TCC 127 (Informal Procedure)

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Revenue and Customs Commissioners v. First Nationwide, [2012] BTC 99, [2012] EWCA Civ 278

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Tax Topics - General Concepts - Substance 71

Marshall v. The Queen, 2011 DTC 1353 [at 1976], 2011 TCC 497

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Capancini v. The Queen, 2010 DTC 1394 [at 4569], 2010 TCC 581 (Informal Procedure)

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Morasse v. The Queen, 2004 DTC 2435, 2004 TCC 239 (Informal Procedure)

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Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 110
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend distributions out of share premium based on number of shares held were dividends 211

Robwaral Ltd. v. MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC)

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Words and Phrases
received
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Tax Topics - General Concepts - Payment & Receipt dividend not received until cheque received 39

Administrative Policy

25 August 2014 External T.I. 2014-0528361E5 - premium on redemption of foreign affiliate shares

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend redemption premium is proceeds 70

30 April 2013 Internal T.I. 2012-0439741I7 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend treatment of MRPS as equity 194
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share treatment of MRPS as equity 180

12 July 2011 External T.I. 2010-0391621E5 - Capital Gains Distributions

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21 October 2004 Internal T.I. 2004-006013 -

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31 August 1999 APFF Roundtable Q. 3, 5-992092 -

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28 October 1997 T.I. 971196 [distribution treatment turns on US corporate law]

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Income Tax Technical News, No. 11, September 30, 1997, "U.S. Spin-Offs (Divestitures) - Dividends in Kind"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) 21

8 January 1996 T.I. 942802 [all distributions from Delaware corps are dividends]

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) all distributions from Delaware corps are dividends 90

7 June 1994 T.I. 9415515 [capital distribution by Delaware corp]

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) capital distribution by Delaware corp 135

24 March 1994 T.I. 940285

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Subsection 90(2) - Dividend from foreign affiliate

Administrative Policy

2016 Ruling 2015-0617351R3 - payments under a German profit transfer agrmt “PTA"

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(8.1) survivor merger of two German CFAs 42

11 April 2017 Internal T.I. 2016-0670541I7 - Foreign affiliate share redemption

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend redemption proceeds might in part be a dividend under Barbados law 131
Tax Topics - Income Tax Act - Section 95 - Subsection 95(6) - Paragraph 95(6)(b) skewing exempt surplus to Canco could engage s. 95(6) 126

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 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

26 May 2016 IFA Roundtable Q. 6, 2016-0642081C6 - German Organschafts

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) profit transfer payments made by a German sub to German parent are s. 90(2) dividends not within s. 95(2)(a)(ii)(B) after 2016 147
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) German profit transfer payment to loss subsidiary is contribution of capital 154
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) loss compensation payment under Organschaft 121

8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares

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Words and Phrases
equity
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share MRPS (Luxembourg hybrid instruments which were “very similar to traditional shares under Canadian business corporations statutes”) were equity 705

2015 Ruling 2014-0527961R3 - Deemed dividend under subsection 90(2)

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17 June 2014 External T.I. 2013-0506731E5 - Immigration

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt note satisfied dividend 77
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) dividend receivable acquired on immigration 137

2013 Ruling 2012-0463611R3 - Foreign Divisive Reorganization

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23 May 2013 IFA Round Table, Q. 2

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Articles

Melanie Huynh, Paul Barnicke, "German Organschafts", Canadian Tax Highlights, Vol. 24, No. 6, June 2016, p. 5

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Michael Gemmiti, "FA Dividends Must be Pro Rata", Vol. 3, No. 3, August 2013, p. 7

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Patrick W. Marley, Kim Brown, "Foreign Mergers and 'Demergers' Under Recent Canadian Proposals", Tax Management International Journal, 10 February 2012, Vol 41, No. 2, p. 86

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Geoffrey S. Turner, "Upending the Surplus Ordering Rules: Implications of the New Regulation 5901(2)(b) Election", CCH Tax Topics, No. 2079, p. 1, 12 January 2012

Elaine Buzzell, "Distributions of Share Premium by Foreign Affiliates", Corporate Finance, Vol. XVII, No. 2, 2011, p. 1962

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Subsection 90(3) - Qualifying return of capital

Commentary

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Administrative Policy

20 March 2015 External T.I. 2014-0535971E5 - Meaning of "paid-up capital" in subsection 90(3)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital LLC with partner capital-account style LLC Agreement does not have PUC 68

6 December 2011 TEI Roundtable Q. 5, 2011-0427001C6 - 2011 TEI Q#5 - Distributions from Foreign Corp.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) share premium 26

2004 Miscellaneous 2004-0065921R3 - Conversion of corporations into LLCs

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition conversion into California or Delaware LLC 102

9 May 2002 Internal T.I. 2002-0135307 F - Application du paragraphe 39(2)

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8 January 1996 T.I. 942802 [all distributions from Delaware corps are dividends]

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) all distributions from Delaware corps are dividends 90

7 June 1994 T.I. 9415515 [capital distribution by Delaware corp]

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) capital distribution by Delaware corp 135

Subsection 90(4) - Connected person or partnership

Articles

David Bunn, Sandra Slaats, "A Critique of Proposed Subsections 90(4) to (10)", International Tax Planning, Vol XVII, no. 1, 2011

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Drew Morier, "Canadian Proposals Mark a Decade of Changes to the Foreign Affiliate Rules", Journal of International Taxation, January 2012, p.26

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Jason D. Durkin, "Upstream Loan Rules - Why Now?", CCH Tax Topics, No. 2073, 1 December 2011, p. 1

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Sandra Slats, David Burns, "Canada Considers New Rules on Repatriation", Tax Notes International, Vol 63, No. 9, 29 August 2011, p. 641

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Subsection 90(6) - Loan from foreign affiliate

Administrative Policy

4 August 2016 Internal T.I. 2016-0645521I7 - 90(6) & sale of creditor affiliate

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) deduction not dependent on FA being creditor affiliate at repayment time 209

30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan

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14 November 2013 External T.I. 2013-0499121E5 - upstream loan

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22 May 2014 May IFA Roundtable, 2014-0526731C6 - IFA 2014 Q. 3bb - Upstream Loan

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22 May 2014 IFA Roundtable, 2014-0526751C6 - Adjusted cost base of foreign affiliate shares

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) no relief from interest and penalties 109
Tax Topics - Income Tax Act - Section 92 - Subsection 92(5) no administrative relief even where rollover at partnership level 172

22 May 2014 IFA Roundtable, 2014-0526751C6 - Adjusted cost base of foreign affiliate shares

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) s. 90(6) relationship tested at time of loan 353
Tax Topics - Income Tax Act - Section 92 - Subsection 92(5) no administrative relief even where rollover at partnership level 172

Articles

Clara Pham, "An Unpaid Amount Could Be an Upstream Loan", Canadian Tax Focus, Vol. 5, No. 3, August 2015, p.5.

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Paul Barnicke, Melanie Huynh, "Upstream Loans: CRA Update", Canadian Tax Highlights, Vol. 21, No. 12, December 2013, p. 3

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Ken J. Buttenham, "Are you Ready for the Upstream Loan Rules?", Canadian Tax Journal, (2013) 61:3, 747-68

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Subsection 90(6.1)

Subsection 90(7) - Back-to-back loans

Administrative Policy

26 May 2016 IFA Roundtable, Q. 5

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Paragraph 90(7)(a)

Administrative Policy

John Lorito and Trevor O'Brien, "International Finance – Cash Pooling Arrangements," draft version of paper for CTF 2014 Conference Report.

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Subsection 90(8) - Exceptions to subsection (6)

Paragraph 90(8)(a)

Administrative Policy

2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) loan repayment not part of a prohibited series 139
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition automatic loan renewals did not entail the making of new loans 56

3 March 2017 Internal T.I. 2016-0673661I7 - Upstream loans – allocation of repayments

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26 May 2016 IFA Roundtable Q. 4, 2016-0642151C6 - Upstream loan converted to PLOI

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Words and Phrases
series

24 November 2015 CTF Roundtable Q. 8, 2015-0610621C6 - FA Liquidation and upstream loans

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24 November 2013 CTF Roundtable, 2013-0508151C6 - Upstream Loans

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt repayment by set-off 73

2013 Ruling 2013-0491061R3 - Upstream Loans

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(25) - Paragraph 212.3(25)(b) s. 212.3(25)(b) avoids acquisition on partnership winding-up 365

Articles

Geoffrey S. Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7

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Subsection 90(9) - Corporations: deduction for amounts included under subsection (6) or (12)

Administrative Policy

20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation - Paragraph (a) s. 80 non-application where s. 90(6) applies to forgiven loan even if offsetting surplus deduction 148
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) debt forgiveness not a repayment 54

28 May 2015 IFA Roundtable Q. 4, 2015-0581501C6 - Upstream loans: ss. 90(9) deduction

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30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) no double inclusion following FA creditor wind-up 54
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3) notional s. 40(3) gain does not generate surplus 59
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) no double inclusion following FA creditor wind-up or for 2nd loan in series 105
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(1.1) notional Reg. 5901(1.1) election 24
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(a) 90-day rule unavailable 22
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b) notional Reg. 5901(2)(b) election 25
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Underlying Foreign Tax notional UFT disproportionate election 31

22 May 2014 May IFA Roundtable Q. 3a, 2014-0526721C6 - IFA 2014 Q. 3a(a) - Upstream Loan

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22 May 2013 IFA Roundtable, 2013-0483791C6 - Upstream Loans

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Articles

Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper

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Geoffrey S. Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7

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Geoffrey S. Turner, "Upstream Loans and Dispositions of Foreign Affiliate Shares", International Tax (Wolters Kluwer CCH), No. 85, December 2015, p.1

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Ian Bradley, Marianne Thompson, Ken J. Buttenham, "Recommended Amendments to the Upstream Loan Rules", Canadian Tax Journal, (2015) 63:1, 245-67.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) 678

Ken J. Buttenham, "Are you Ready for the Upstream Loan Rules?", Canadian Tax Journal, (2013) 61:3, 747-68

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Finance

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Subsection 90(10)

Articles

Michael Spinelli, Karthika Ariyakumaran, "Upstream Loans Disadvantage Corporate Members of a Partnership", Canadian Tax Focus, Volume 8, Number 4, November 2018, p.5

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Subsection 90(14) - Repayment of loan

Administrative Policy

2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a) subsequent intercorporate loans and discharges were not part of “series of loans or other transactions and repayments” 262
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition automatic loan renewals did not entail the making of new loans 56

20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules

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Words and Phrases
repayment
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) potential indefinite application of surplus where upstream loan forgiven after FA sale 187
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation - Paragraph (a) s. 80 non-application where s. 90(6) applies to forgiven loan even if offsetting surplus deduction 148

4 August 2016 Internal T.I. 2016-0645521I7 - 90(6) & sale of creditor affiliate

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) inclusion not dependent of maintenance of creditor affiliate status 71

22 May 2014 May IFA Roundtable, 2014-0526741C6 - Foreign affiliates - upstream loans

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2013 Ruling 2013-0477871R3 - 5900(1)(a) and dividends from foreign affiliate

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(11.2) dividends from Malaysian offshore company 308

Finance

1 May 2018 Finance Comfort letter respecting repayment of back-to-back loans under the upstream loan rules

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16 May 2018 IFA Finance Roundtable, Q.10

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Articles

Ian Bradley, Marianne Thompson, Ken J. Buttenham, "Recommended Amendments to the Upstream Loan Rules", Canadian Tax Journal, (2015) 63:1, 245-67.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) 702

Ken J. Buttenham, "Are you Ready for the Upstream Loan Rules?", Canadian Tax Journal, (2013) 61:3, 747-68

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Finance

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Subsection 90(15) - Definitions

Articles

specified debtor

(b)

Administrative Policy

2014 Ruling 2013-0510551R3 - Upstream Loans - Specified Debtor

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