Prior to 2011, upstream loans were used to defer income offshore by having a foreign affiliate make a loan to a Canadian shareholder. In 2011, the government introduced upstream loan rules (grandfathered to take effect on August 20, 2016 for loans made prior …Upstream Loan means the intra-group loan to be granted by the Issuer to the Parent, immediately after the Issuer has received the proceeds of the Notes, for the purpose of the Parent refinancing its pertaining to “upstream loans” made by foreign affiliates of Canadian companies. Finance has described the new upstream loan rules as “protecting the integrity” of the existing taxable surplus and the new hybrid surplus regimes, as well as ensuring that pre‐acquisition surplus capital gainsUpstream Loans means any intercompany balances from time to time owed by any Obligor (other than the Borrower, the Vessel Owner or any Person becoming an Additional Obligor) or Tidewater Marine International, Inc. to the Borrower, the Vessel Owner or any Person becoming an Additional Obligor. Sample 1. Based on 1 documents. Remove ;· an upstream loan from a foreign affiliate in a manner equivalent to a dividend, so as to neutralize any Canadian tax incentive to lend funds upstream rather than distribute them as an actualUpstream Loans and Other Indebtedness to Foreign Upstream Loans and Dispositions of Foreign Affiliate SharesUpstream Loans and Other Indebtedness to Foreign An Unpaid Amount Could Be an Upstream Loan01/02/2007 · When the new Companies Act 2006 came into force last year, several issues related to upstream loans and security (including financial assistance) that had been the subject of debate were clarified. In relation to the general prohibition on loans and security to shareholders by a company (General Prohibition), the Act spells out in detail the scope and meaning of certain exceptions.

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