I-3 - Taxation Act

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174.2. Any amount in respect of interest paid or payable to a controlled foreign affiliate of a corporation resident in Canada that would otherwise not be deductible by the corporation for a taxation year because of section 169 may be deducted to the extent that an amount included under section 580 in computing the corporation’s income for the year or a subsequent year can reasonably be considered to be in respect of the interest.
2015, c. 21, s. 132.