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I-3 - Taxation Act

Section 127.7
Disposition versions

Full text
127.7. For the purposes of this division and subject to section 127.8, a person not resident in Canada is deemed at any time to owe to a corporation resident in Canada an amount equal to the amount, or a portion of the amount, as the case may be, owing to a particular person or partnership where
(a)  the person not resident in Canada owes an amount at that time to the particular person or partnership, other than a corporation resident in Canada; and
(b)  it may reasonably be considered that the amount or a portion of the amount became owing, or was permitted to remain owing, to the particular person or partnership because a corporation resident in Canada made a loan or transfer of property, or the particular person or partnership anticipated that a corporation resident in Canada would make a loan or transfer of property, either directly or indirectly in any manner whatever, to or for the benefit of any person or partnership (other than an exempt loan or transfer).
2001, c. 53, s. 41; 2017, c. 1, s. 92.
127.7. For the purposes of this division and subject to section 127.8, a person not resident in Canada is deemed at any time to owe to a corporation resident in Canada an amount equal to the amount owing to a particular person or partnership where
(a)  the person not resident in Canada owes an amount at that time to the particular person or partnership, other than a corporation resident in Canada; and
(b)  it may reasonably be considered that the particular person or partnership entered into the transaction under which the amount became owing or the particular person or partnership permitted the amount owing to remain outstanding because a corporation resident in Canada made a loan or transfer of property, or the particular person or partnership anticipated that a corporation resident in Canada would make a loan or transfer of property, either directly or indirectly in any manner whatever, to or for the benefit of any person or partnership, other than an exempt loan or transfer.
2001, c. 53, s. 41.
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