Business Vocabulary
Q1
Loans from a foreign parent to a Canadian subsidiary cannot fit within the exemption, so corporations have attempted to structure intercorporate debt in other ways, including '.....' loans, where cash is loaned from a foreign parent to an arm's length foreign company that then lends to the Canadian subsidiary.
(*) back-to-back
(*) belly-to-belly
(*) side-to-side
(*) top-to-bottom