Loans from a foreign parent to a Canadian subsidiary cannot fit within the exemption, so corporations have attempted to structure intercorporate debt in other ways, including '.....' loans, where cash is loaned from a foreign parent to an arm's length foreign company that then lends to the Canadian subsidiary. (*) back-to-back (*) belly-to-belly (*) side-to-side (*) top-to-bottom
This is a companion discussion topic for the original entry at https://english.best/questions/10227,loans-from-a-foreign-parent-to-a-canadian-subsidiary-cannot-fit-within-the-exemption-so-corporations-have-attempted-to-structure-intercorporate-debt-in-other-ways-including-___-loans-where-cash-is-loaned-from-a-foreign-parent-to-an-arms-length-foreign-company-that-then-lends-to-the-canadian-subsidiary/