Tax-Indifferent Investor

Para. (b) should refer to payments under either a synthetic equity arrangement or a derivative forward agreement, as the case may be, that are connected to a Canadian permanent establishment.
Re para. (c), it is counter-intuitive to suggest that every discretionary trust is tax-indifferent.
Anomalies can also arise under paras. (d) and (e), e.g., for a partnership held on an 85/15 basis by a taxable Canadian corporation and pension fund.

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(1) - Paragraph 212.3(1)(b)		189
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(16)		95
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(26)		147
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(c) - Subparagraph 212.3(18)(c)(ii)		53
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2.1)		7
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii)		22
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11)		32
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(z.7)		58

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