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Section 76.1 | Tax Interpretations Skip to main content

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Section 76.1

Table of Contents

Subsection 76.1(1) - Non-resident moving debt from Canadian business

Administrative Policy(1)

Subsection 76.1(1) - Non-resident moving debt from Canadian business

Administrative Policy

16 September 2011 T.I. 2010-038357 -

s. 76.1 would not apply to a "loan" between the US head office of a US corporation and its Canadian branch that is now being closed down, as such loan would not be considered to exist.

Articles

Orest Moysey, Stan Mag, "New Canadian Branch Making Rules for Foreign Banks: Opportunities and Issues", International Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 6, p. 1869.

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