CPA Canada’s response to Finance Canada’s proposals for taxing foreign affiliates

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

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CPA Canada has weighed in on Finance Canada’s December 18, 2009 draft legislation and regulations featuring technical amendments to how it taxes Canadian corporations with foreign affiliates. Developed by the Joint Committee on Taxation of the Canadian Bar Association and CPA Canada, this February 15, 2010 submission paper raises key concerns about the proposals, and offers several constructive recommendations to make them more effective.

What you will learn

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

  • foreign affiliate elections deadlines
  • subsection 93(1) and the former deficit reallocation rules
  • fill-the-hole rules
  • bump room and grind for tax-free surplus
  • designated treaty country
  • foreign accrual property losses and prescribed foreign accrual tax


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