The Resource Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates

Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates

Label
Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates
Title
Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates
Creator
Subject
Language
eng
Summary
The purpose of this article is to provide a consolidated overview of stop-loss rules that are of particular relevance in the cross-border and foreign affiliate contexts. The author reviews selected transactions to illustrate the various issues, anomalies, and potential traps that can arise as a result of the interaction of the stop-loss rules with the foreign affiliate regime. He also reviews certain aspects of the new functional currency regime in section 261, which may be used to help manage the foreign exchange risk of a multinational group in some cases and thus limit the Canadian tax exposure that might arise from the application of the stop-loss rules to transactions involving foreign affiliates
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 58 (2010), no. 4 ; p. 897-925
http://library.link/vocab/creatorName
Samuel, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • stop loss rules
  • foreign exchange
  • foreign accrual property income
  • loan
Label
Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates
Instantiates
Publication
Label
Stopping the losses : the application of stop-loss rules to transactions involving foreign affiliates
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...