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You are going to email the following CRA finds that interest paid by a US Opco FA to a Finco FA would qualify under s. 95(2)(a)(ii)(B)(I) even if the IRC denied the deduction or required its capitalization to depreciable property

Message Subject (Your name) has forwarded "CRA finds that interest paid by a US Opco FA to a Finco FA would qualify under s. 95(2)(a)(ii)(B)(I) even if the IRC denied the deduction or required its capitalization to depreciable property" - Tax Interpretations

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