CPA Canada’s response to Finance Canada’s legislative proposals regarding foreign affiliates

Learn about Chartered Professional Accountants of Canada (CPA Canada)’s submission to the federal government in response to its draft legislative proposals relating to foreign affiliates.

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CPA Canada has weighed in on the Department of Finance’s August 16, 2013 draft legislative proposals for international tax laws within the Income Tax Act that would impact foreign affiliates. Developed by the Joint Committee on Taxation of the Canadian Bar Association and CPA Canada, this submission paper responds to the government’s proposed tax legislation, and provides several constructive recommendations to improve their effectiveness.

What you will learn

Committee members provide their expert insights on tax topics such as:

  • thin capitalization relief
  • paid-up capital offset
  • cross-border class shares
  • simultaneous loss of parent control
  • reduction of deemed dividend
  • deferred control transaction
  • indirect financing
  • debt conversions
  • non arm’s-length acquisitions
  • sequential investments


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