A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where the gross-up is paid or credited to the government of a foreign country on the Canadian lender's behalf since the Canadian lender would have constructively received the gross-up".
Topics and taglines
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
324430
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
341281
Extra import data
{
"field_editor_tags": [],
"field_roundtable_subquestion": "",
"field_stub": false,
"field_legacy_header": "5 January 1996 Memorandum 952397 (C.T.O. \"Gross-Up Payments\")"
}
"field_editor_tags": [],
"field_roundtable_subquestion": "",
"field_stub": false,
"field_legacy_header": "5 January 1996 Memorandum 952397 (C.T.O. \"Gross-Up Payments\")"
}