The Resource The anti-tax-haven initiative and the foreign affiliate rules

The anti-tax-haven initiative and the foreign affiliate rules

Label
The anti-tax-haven initiative and the foreign affiliate rules
Title
The anti-tax-haven initiative and the foreign affiliate rules
Creator
Subject
Language
eng
Summary
In the federal budget presented to the Canadian House of Commons on March 19, 2007, Finance Minister Jim Flaherty proposed to effectively eliminate the ability to deduct interest on borrowings relating to investments in foreign affiliates. In response to widespread criticism, on May 14, 2007, Minister Flaherty announced a substantially revised and more narrowly focused interest denial rule. The revised proposal, referred to as the anti-tax-haven initiative (ATHI), has as its primary objective the prevention of "doubledipping"- the generation of two (or more) interest expense deductions in respect of one investment. The authors of this article examine the mechanics of the ATHI, including its practical limitations, and explore issues concerning the future integration of the ATHI with the foreign affiliate regime and other provisions of the Income Tax Act
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 55 (2007),
http://library.link/vocab/creatorName
  • Huynh, M
  • Lockwood, E
  • Maikawa, M.J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • double dipping
  • tax haven
  • interest deduction
  • affiliated company
  • partnership
Label
The anti-tax-haven initiative and the foreign affiliate rules
Instantiates
Publication
Label
The anti-tax-haven initiative and the foreign affiliate rules
Publication

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