CPA Canada’s response to Finance Canada’s foreign affiliate proposals

Learn about Chartered Professional Accountants of Canada (CPA Canada)’s submission to the federal government about its proposed legislation amendments affecting foreign affiliates.

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CPA Canada has provided input to Finance Canada about its draft legislative proposals regarding foreign affiliates. Developed by the Joint Committee on Taxation of the Canadian Bar Association and CPA Canada, this October 19, 2011 submission paper raises concerns about the nature and scope of the proposed amendments, and provides several technical recommendations to make them more effective.

What you will learn

Committee members provide their expert insights on aspects of the proposed legislation, such as:

  • foreign exchange gains and losses
  • hybrid surplus rules
  • reinstatement of loss triggered on repayment of debt
  • foreign affiliate distributions
  • upstream loan rules
  • foreign affiliate liquidations
  • absorptive mergers
  • prescribed foreign accrual tax


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