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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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  • 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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