Canada Corp. is owned 100% by specified non-residents. The existing equity in the corporation (beginning retained earnings,

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Canada Corp. is owned 100% by specified non-residents. The existing equity in the corporation (beginning retained earnings, the monthly average of beginning contributed surplus by specified non-residents, and the monthly average of beginning paid-up capital of the specified non-residents’ shares) is $200,000. Interest paid in the year on a $1 million debt (average of the greatest amount of debt for each month) due to the specified non-resident shareholders was $125,000 for 2016.


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What is the impact, if any, of the thin capitalization rule on the corporation’s 2016 Division B income calculation?

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Introduction To Federal Income Taxation In Canada 2016-2017

ISBN: 9781554968725

37th Edition

Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett

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