Eric Lockwood, Michael J. Maikawa and Nick Pantaleo of PricewaterhouseCoopers LLP, Toronto, review and analyze the proposed changes announced by the Department of Finance on November 30,1999, on the proposals dealing with foreign corporations held through partnerships in which a corporation resident in Canada or a foreign affiliate of a corporation resident in Canada is a member.
Introduction
On November 30, 1999, the Department of Finance released a package of proposed technical amendments to the Income Tax Act.1 The proposed amendments are intended to correct or clarify the application of existing income tax provisions, implement measures that had already been announced, or deal with other situations that require a legislative policy response.