Category: Canco

Canada / Canco / Dividends / Offshore Partnerships / Shares / Statutory / Withholding tax rules

Canada: ACB Adjustments For Foreign Affiliate Shares Held Through Partnerships

Posted On: November 6, 2015

Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading

Canada / Canco / Court cases / Double Tax Treaty / Legislation / Loans / USA / USLP

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Posted On: October 7, 2014

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

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