Subsection 18.4(1)
Canadian Ordinary Income
Paragraph (a)
Subparagraph (a)(iii)
Articles
Joint Committee, "Hybrid Mismatch Arrangements Proposals", 30 June 2022 Submission of the Joint Committee
Ambiguity as to whether general deductions come within the (a)(iii)(A) and (B) exclusions (under 4. “Canadian Ordinary Income” & “Foreign...
Specified Entity
Articles
Joint Committee, "Hybrid Mismatch Arrangements Proposals", 30 June 2022 Submission of the Joint Committee
More explicit exclusion needed for mere security arrangements (under “9. Proposed Subsection 18.4(17) & Security Interests”)
The “specified...
Subsection 18.4(3)
Articles
Joint Committee, "Hybrid Mismatch Arrangements Proposals", 30 June 2022 Submission of the Joint Committee
Recommended exclusion of ss. 12.7 and 18.4 from the foreign affiliate context (under “3. Application to Foreign Affiliates”)
- Where, for...
Subsection 18.4(9)
Articles
Joint Committee, "Hybrid Mismatch Arrangements Proposals", 30 June 2022 Submission of the Joint Committee
Potential double taxation through considering there to be a mismatch where the amount is deductible (but not actually deducted) in the foreign...
Subsection 18.4(10)
Articles
Simon Townsend, Silvia Wang, "Can the Hybrid Mismatch Rules Affect Canadian ULCs?", International Tax Highlights, Vol. 3, No. 1, February 2024, p. 5
Example 1 (p. 5)
- A US C corporation (“US Parent”) wholly owns a Canadian ULC (“Cansub”) that is disregarded in the U.S. and to which it...