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CPA Canada has provided feedback on the Department of Finance’s July 25, 2012 draft legislative proposals for a range of technical amendments to the income tax laws, including the introduction of section 18.3 to address “stapled security” structures. The government’s stated aim with these proposals is to strengthen and create greater fairness in Canada’s tax system.
Developed by the Joint Committee on Taxation of the Canadian Bar Association and CPA Canada, this submission paper responds to the government’s planned tax law changes, and provides several constructive recommendations to improve their effectiveness.
What you will learn
Committee members provide their expert insights on the proposed changes to the following tax topics:
- amending the definition of a “security”
- amending the definition of a “subsidiary”
- determining the foreign accrual property income of a foreign affiliate
- adjusting the amendment to the excluded subsidiary entity test