Neil Burnside’s article, “Back-to-Back Shareholder Loans Within a Cross-border Affiliated Group,” has been published by Federated Press in Volume XIX, No. 1 of its Corporate Structures and Groups Journal, part of its Corporate Tax Planning Series.
In the paper, Neil explores the history and policy rationale behind the shareholder loan rules and the Back-to-Back Rules, before reviewing how those rules interact with shareholder loans that are repaid within the time prescribed to avoid the application of subsection 15(2).
The Corporate Structures and Groups Journal is devoted to the tax aspects of structuring and restructuring corporation and other business entities. Cassels partner Douglas Richardson is a member of the Editorial Board.