Michael Black, "Cross-Border Consolidation and the Foreign Affiliate Rules", Canadian Tax Journal (2017) 65:1, 173-89

Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (a) - Subparagraph (a)(i)

CCCTB proposal in European Commission draft EU directive package of October 2016 (pp.175-6)

[I]ncluded in that package is a proposal to revamp the...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Taxable surplus

CCCTB proposal in European Commission draft EU directive package of October 2016 (pp.175-6)

[I]ncluded in that package is a proposal to revamp the...

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

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Tax

CCCTB proposal in European Commission draft EU directive package of October 2016 (pp.175-6)

[I]ncluded in that package is a proposal to revamp the...

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

Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1.3) - Paragraph 5907(1.3)(a)

CCCTB proposal in European Commission draft EU directive package of October 2016 (pp.175-6)

[I]ncluded in that package is a proposal to revamp the...

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