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  • Ploi - Server Management Tool
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  • Understanding interest - Canada. ca
    Pertinent loans or indebtedness (PLOI) The Income Tax Act (the Act) contains a number of rules in relation to loans or indebtedness which can apply in the context of cross-border transactions This guidance deals with pertinent loan or indebtedness (PLOI) elections, which are relevant for the purposes of sections 15 and 212 3 of the Act
  • Recent changes to pertinent loan or indebtedness (PLOI) elections
    On March 25, 2022, the Canada Revenue Agency (the “CRA“) issued a notice to tax professionals outlining certain changes to “pertinent loan or indebtedness” (“PLOI“) elections, including PLOI elections made in respect of cross-border shareholder loans under subsection 15(2 11) of the Income Tax Act (the “ITA“)
  • Canada: Prescribed rates of interest for income tax, PLOI . . . - KPMG
    An increase to the prescribed interest quarterly rate that is used to determine the deemed interest income inclusion from a PLOI—the rate is estimated to increase to 8 99% (from 8 44%) for the fourth quarter of 2023
  • CRA provides for expanded PLOI election disclosure and permits PLOI . . .
    Where a pertinent loan or indebtedness (PLOI) election is made under s 15(2 11) or 212 3(11) respecting an amount owing by a corporation resident in Canada (CRIC) to certain non-residents, the loan or indebtedness will be subject to notional interest imputation rules instead of potentially being treated as a deemed dividend paid by the CRIC to
  • Cross-border debt financing - an overview of Canadian tax implications
    Exception - Pertinent Loan Or Indebtedness (PLOI) Regime Under the PLOI Regime, a shareholder loan that would otherwise be subject to the shareholder loan rules can be exempted if the loan meets the following general criteria:
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    Ploi offers many features to make your life as developer as easy as possible to setup sites and servers Fast Provisioning Quickly provision servers and deploy sites with DigitalOcean, UpCloud, Vultr, Linode, Scaleway, AWS EC2, or Custom VPS
  • T1521 Election for a Pertinent Loan or Indebtedness (PLOI . . . - Canada
    T1521 Election for a Pertinent Loan or Indebtedness (PLOI) under Subsection 15(2 11) Download instructions for fillable PDFs
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  • Pertinent Loan or Indebtedness Regime | Miller Thomson
    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





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