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International Tax Newsletter

Related Services

Insights / Communiqués / International Tax Newsletter / November 2012 / Pertinent Loan or Indebtedness Regime
November 2012 | John M. Campbell

IN THIS SECTION:

As discussed above, PLOI is excepted from the adverse application of section 212.3. PLOI is also excepted from the adverse application of subsection 15(2) of the Act, although the indebtedness that qualifies for the PLOI exception from subsection 15(2) is different than that which is excepted from section 212.3.

Subsection 15(2) and paragraph 214(3)(a) of the Act generally deem (subject to various exceptions) indebtedness 12 owing to a Canadian resident corporation ( “Canco” ) or a resident corporation not dealing at arm’s length with Canco by a non-resident shareholder of Canco or a non-resident person not dealing at arm’s length with a shareholder of Canco to be a shareholder benefit subject to Canadian withholding tax if not repaid within one year after the end of the taxation year of the relevant Canadian creditor in which the indebtedness arose. 13 Indebtedness that is PLOI is excluded from the application of this rule under subsection 15(2.11) of the Act.

“Canco”

Back to top

The PLOI exception in subsection 15(2.11) applies if all of the following conditions are met:

“NR Debtorco” Qualifying Canadian Partnership PLOI Elections

The exception from subsection 15(2) for PLOI is not automatic. Where the amount is owed to a CRIC, the CRIC and the non-resident corporation that controls the CRIC must jointly elect under subparagraph 15(2.11)(d)(i) of the Act for debt to be PLOI. If the amount is owed to a Qualifying Canadian Partnership, all of the members of the partnership and the non-resident corporation that controls the CRIC must jointly elect under subparagraph 15(2.11)(d)(ii) for debt to be PLOI.

The PLOI Elections must be made by the non-resident corporation that controls the CRIC even if the amount is owed by another NR Debtco in the group or by a partnership of which another non-resident corporation in the group is a member.

The PLOI Elections are made on a debt by debt basis for qualifying debtor/creditor relationships. It does not appear that the election can be revoked.

The PLOI election under subparagraph 15(2.11)(d)(i) must be filed with the CRA on or before the income tax return filing-due date of the CRIC for the CRIC’s taxation year in which the post-March 28, 2012 debt becomes owing to the CRIC by the relevant NR Debtco. The subparagraph 15(2.11)(d)(ii) PLOI election must be filed with the CRA on or before the income tax return filing-due date of the CRIC for the CRIC’s taxation year in which the fiscal period of the Qualifying Canadian Partnership ends and during which the post-March 28, 2012 debt becomes owing by the relevant NR Debtco. Late filing of the election is permitted within three years after the filing deadline if a late filing penalty is paid. 14

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Construct™ 120 80 Structures

Construct™ 120 80 Structures

Item # CON120
Or Call
(800) 341-1557

Non-linear designs

Moss employs a unique manufacturing process and specialized equipment to bend the Construct framing systems to execute non-linear designs and angled corners. Construct 120 80 are significantly stronger than system groove locks and snap frames for fabricating large scale tension fabric structures.

Smooth Finish - minus the groove

Because cladding extrusion is only added where it is needed, the rest of the surfaces are left smooth, eliminating the need to hide unused system grooves.

Light + Nimble

Building 20’, 30' and 40' spans without vertical support unleashes creativity, maximizes space utilization and minimizes material requirements - Construct 120 can span 30' (at minimal load) without vertical support, and when used in an I-beam style double-beam spreader configuration can span up to 40' without vertical support (minimal load). Construct 80 can span 20' (at minimal load) without vertical support, and when used in an I-beam style double-beam spreader configuration can span up to 30' without vertical support (minimal load). Less drayage and faster installation mean more budget for designing the ideal exhibit. Cost savings at future shows are rapidly realized.

Height Without Hangpoints

Eliminate costly rigging labor and potential delays while highlighting your company with impactful branding. The Construct System is ideal for showcasing branding with 10’ high seamless graphics and no need for rigging.

Efficient, Exclusive Pull-Tite™ Locks

Proprietary Pull-Tite locks deliver amazingly fast, secure and simple frame assembly. The best part: no small, loose parts.

Built-in Brilliance

plug-and-play Illuminedge LED lightbox technology is integrated to impressively backlight fabric panels. Available integrated lighting solutions also include the LED Color Wash Wall, dynamic and programmable with 4,000+ colors. Each eye-catching lighting solution features plug-and-play efficiency and pre-run hidden wiring that saves on site electrical costs.

Advanced Design

Several design differentiators immediately set the Construct System apart. Along with its ability to span great distances without support, it is the fastest-installing channel-less extrusion with modern, clean and elegant lines. It is also the largest bendable extrusion available, creating organic curves resulting in a sleek, artfully attractive booth with superior functionality. This product is covered by one ore more pending U.S. Patent(s) owned by Moss Holding Company.

Design Outdoors!

Construct 120™ is now available for custom outdoor structures. All outdoor structures are certified by a structural engineer. Create outdoor temporary and portable 3D structures for branding and wayfinding including arches up to 20 ft. high.

Custom Rental

The Construct System is perfect for creating modern, large-scale custom structures, clad however you like with fabric and a variety of available materials. It is also available with standard Rental Post Beam sizes to build large-scale with a design-centric rental solution. Learn more about all of our rental products and LAURENCE DACADE Woman Nelly Leathertrimmed Lace Sandals Size 395 New Arrival Cheap Price Discount Pay With Paypal Sale 2018 Free Shipping Outlet Sale 2zYB0FGcj
.

Frame - 120mm, Square, Smooth aluminum extrusion

100% Satisfaction

It's more than our guarantee...IT'S OUR POLICY!

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Albuquerque Florist (505) 881-3336

3121 San Mateo NE Albuquerque, NM 87110 Albuquerque Florist (505) 338-0038 1416 Juan Tabo NE Albuquerque, NM 87112 Mon - Fri: 8:00am - 5:30pm Sat: 8:00am - 4:00pm Sun: Closed

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