45 becausenosafe harbourruleisincludedinarticle

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Unformatted text preview: financing company is derived in connection with a trade or business if it is attributable to income-producing activities of a group of companies whose line of business forms part of or is complementary to a trade or business of connected affiliates.39 although the Cra acknowledged that consideration will be 37 supra note 7. 38 supra note 17. 39 see irs private letter ruling (PLr) 200525002, March 25, 2005, and PLr 200620017, February 9, 2006. 102 n c anadian tax journal / revue fiscale canadienne ( 2009) vol. 5 7 , n o 1 FIGURE 2 Corporate Structure in Technical Interpretation EUco Country A United States US Holdco Dividends (3) CanULC Canada United States Dividends (2) USco Dividends (1) US Opcos US active business given to the interpretive approach adopted by the united states, clear written guidance in Canada to support such a broad interpretive approach is lacking. it is conceivable that the Cra could adopt interpretive tests that resemble the rule in subparagraph 95(2)(a)(i) of the act. This rule deems payments received by an affili...
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This note was uploaded on 11/03/2013 for the course ACCOUNTING 346 taught by Professor William during the Fall '12 term at DeVry Chicago.

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