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ARTICLE · 25 JANUARY 2010

Canadian Foreign Affiliates — New Draft Rules

McCarthy Tétrault
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On December 18, 2009, Canada’s Minister of Finance released draft regulations relating to the taxation of Canadian multinationals with foreign affiliates.

CanadaTax
Marc Darmo
Marc Darmo
Gabrielle Richards
Gabrielle Richards
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On December 18, 2009, Canada's Minister of Finance released draft regulations relating to the taxation of Canadian multinationals with foreign affiliates. This release deals with some of the proposals announced in 2001, 2002, 2004 and 2007; not included, however, are the anticipated changes to the foreign affiliate rules for mergers and other reorganizations that were proposed in 2004. These changes will be the subject of a separate release, to be issued in the near future. The public has until February 15, 2010 to provide comments to the Department of Finance.

Summary of Proposed Regulations

The following is a summary of the various proposed provisions of Part LIX of the regulations to the Income Tax Act:

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