The Resource Proposed upstream loan rules for Canada's foreign affiliate regime

Proposed upstream loan rules for Canada's foreign affiliate regime

Label
Proposed upstream loan rules for Canada's foreign affiliate regime
Title
Proposed upstream loan rules for Canada's foreign affiliate regime
Creator
Subject
Language
eng
Summary
This article discusses proposed Canadian rules designed to discourage transactions that avoided Canadian taxation on taxable dividends through the use of loans from foreign affiliates to their Canadian shareholders. These new rules (the upstream loan rules) are found in proposed subsections 90(4) to 90(10)
Citation source
In: Tax notes international. - Falls Church. - Vol. 65 (2012),
http://library.link/vocab/creatorName
Biderman, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • upstream loan
  • affiliated companies
  • anti-avoidance
Label
Proposed upstream loan rules for Canada's foreign affiliate regime
Instantiates
Publication
Label
Proposed upstream loan rules for Canada's foreign affiliate regime
Publication

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