Tax-Indifferent Investor

Table of Contents


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

  • Para. (b) should refer to payments under either a synthetic equity arrangement or a derivative forward agreement, as the case may be, that are connected to a Canadian permanent establishment.
  • Re para. (c), it is counter-intuitive to suggest that every discretionary trust is tax-indifferent.
  • Anomalies can also arise under paras. (d) and (e), e.g., for a partnership held on an 85/15 basis by a taxable Canadian corporation and pension fund.