New Notice of Ways and Means Motion to Implement Tax Measures in Economic Action Plan 2014

Par Robert Robillard - 16 octobre 2014

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Department of Finance Canada recently released its latest Notice of Ways and Means Motion. Regarding international taxation, it includes:

  • « Better circumscribing an existing exception from the « investment business » definition in the foreign accrual property income regime by introducing additional conditions for the application of the exception [Section 94, 94.2].
  • Adjusting Canada’s foreign accrual property income rules in order to address offshore insurance swap transactions and ensure that income derived directly or indirectly from the insurance of Canadian risks is taxed appropriately [Section 95].
  • Addressing back-to-back loan arrangements involving an intermediary by adding a specific anti-avoidance rule in respect of withholding tax on interest payments, and modifying an existing anti-avoidance rule in the thin capitalization rules [Subsections 18(6)/(6.1), 212(3.1)/(3.2)/(3.3)]. »

The full NWMM is available here.

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard « at » localhost
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