I-3 - Taxation Act

Section 1082.10.1 Disposition versions

2015-10-26

1082.10.1. Section 1082.4 does not apply to adjust an amount of consideration paid, payable or accruing to a corporation resident in Canada (in this section referred to as the “parent”) in a taxation year of the parent for the provision of a guarantee to a person or a partnership (in this section referred to as the “lender”) for the repayment, in whole or in part, of a particular amount owing to the lender by a person not resident in Canada, if

(a)  the person not resident in Canada is a controlled foreign affiliate of the parent for the purposes of Division VII of Chapter II of Title III of Book III throughout the period in the year during which the particular amount is owing; and

(b)  it is established that the particular amount would be an amount owing described in paragraph a or b of section 127.13 if it were owed to the parent.

2015, c. 24, s. 151.