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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Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) | 40 |