Words and Phrases - "series"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
73
s
85
t
44
u
14
v
8
w
20
y
2
“
1

Michael N. Kandev, John J. Lennard, "Interpreting the Expression 'Arrangement or Transaction' in the Principal Purpose Test of the MLI", International Tax (Wolters Kluwer CCH), June 2019, No. 106, p. 1

Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 7 - Article 7(1)

No Canadian domestic definition of the phrase “arrangement or transaction” (p.3)

While Canada’s ITA uses the words “arrangement” and...

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Words and Phrases
arrangement or transaction series

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

Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a)
the replacement of an “2nd-tier” upstream loan to a non-resident parent by a PLOI will not occur as part of the same series

Canco indirectly distributed $10M of excess cash to its non-resident parent (NRco) in 2010 through a capital contribution by it to a new foreign...

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Words and Phrases
series