2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test -- summary under Disposition

The loan owing by a foreign affiliate to a non-resdient sister had had a maturity date that was automatically extended for consecutive one-year terms unless terminated by either party. The “Additional Information section of this ruling letter stated that these automatic extensions did not result in a new loan being made for the purposes of s. 90(6).