2006 Ruling 2006-0195501R3 - Withholding Tax Exemption -- summary under Subparagraph 212(1)(b)(vii)

A wholly-owned taxable Canadian subsidiary ("Finco") of another taxable Canadian corporation ("ACo") on-lends money borrowed from a non-resident of Canada to a second-tier wholly owned partnership of ACo ("LP #2") with the loan to Finco being secured by a mortgage granted by LP #2, a limited guarantee from ACo and a pledge by ACo of its units in a holding partnership for LP #1. Events of default under the loan to Finco include the cancellation of an operating licence for the business of LP #2, and specified changes in the direct or indirect ownership of Finco.

Ruling that the exemption is available.

Topics and taglines
Topic
Income Tax Act - s. 212(1)(vii)
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
311761
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
343625
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