Subtopics
Administrative Policy
4 August 2016 Internal T.I. 2016-0645521I7 - 90(6) & sale of creditor affiliate
Where a non-resident subsidiary (FA) of Canco has made a loan to a non-resident subsidiary (SisterCo) of Canco’s non-resident parent (Foreign...
| 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 | 215 |
S5-F4-C1 - Income Tax Reporting Currency
Automatic application of loss denial
1.72 ... The rule applies to deny a loss to the taxpayer where the loss can reasonably be considered to be...
| Other locations for this summary | |
|---|---|
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(21) |