ARTICLE · 30 OCTOBER 2012

Comprehensive Income Tax Package Released: Long-Awaited Foreign Affiliate Amendments Included

PwC Management Services LP

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On October 24, 2012, Canada’s Department of Finance (Finance) released a Notice of Ways and Means Motion (NWMM).

CanadaTax

William Holms

Mike Maikawa

On October 24, 2012, Canada's Department of Finance (Finance) released a Notice of Ways and Means Motion (NWMM). This "comprehensive package of technical income tax legislation" implements a variety of outstanding technical tax amendments, including legislative proposals relating to the taxation of Canadian multinational corporations with foreign affiliates. In many ways the NWMM is the culmination of legislative developments that started almost ten years ago.

History

On December 20, 2002, Finance released almost 40 amendments to the Canadian foreign affiliate and foreign accrual property income regime. Unfortunately, the legislative package that followed on February 27, 2004, to address the anomalies and issues in the 2002 proposals only created even more anomalies and issues.

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