Joint Committee, "Foreign Affiliate Dumping, Derivative Forward Agreement and Transfer Pricing Amendments Announced in the 2019 Federal Budget", 24 May 2019 Submission of the Joint Committee

  • It is understood that the expansion to non-resident controlling individuals or non-arm’s length groups is not aimed principally at CRICs...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • Given the practical infeasibility of complying with the “more closely connected business” (“MCCB”) exception, a replacement relieving...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • The existing s. 212.3(16) exception is simply unworkable where the deemed “controlling” person is a trust beneficiary. In addition, s....

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • An example of the (likely, many) anomalies that will occur in the operation of the reorganization rules if the scope of the s. 212.3(1) scoping...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • Para. (b) should refer to payments under either a synthetic equity arrangement or a derivative forward agreement, as the case may be, that are...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • The amendment to s. 152(4)(b)(iii) should be made applicable to taxation years ending on or after March 19, 2019.
  • The ss. 15(2) and (2.11) rules should permit PLOI loans to be made by a CRIC to any non-resident person who is a “parent” under the expanded...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

  • The appropriate consequence of failing to meet the commercial transaction exception solely as a result of the new limitation is that only the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.