Ian Bradley, Seth Lim, "The Updated Hybrid Mismatch Rules", International Tax Highlights (Canadian Tax Foundation and IFA Canada), Vol. 3, No. 1, February 2024. p. 2

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Property Income - A - Paragraph (b)

Double taxation under A(b) (p. 3)

  • The inclusion in foreign accrual property income (FAPI) of a foreign affiliate (FA) by virtue of A(b) of the...

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Summary Under
Tax Topics - Income Tax Act - Section 227 - Subsection 227(6.3)

Relief under s. 227(6.3) where reversal of primary, but not secondary, rule mismatch (p.4)

  • Where s. 214(18) deemed interest paid by a Canadian...

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