In Print: Good News for Barbados Qualifying Insurance Companies

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The Canada Revenue Agency has issued a technical interpretation confirming that a Barbados qualifying insurance company (QIC) that is a controlled foreign affiliate of a Canadian-resident corporation will be considered a resident of Barbados under Part LIX of the Income Tax Regulations to the Income Tax Act (Canada). The CRA states that the QIC will be liable to tax in Barbados and provided that it was “centrally managed and controlled” there, the company can be considered a Barbados resident for purposes of Article IV of the Canada/Barbados Double Taxation Treaty.

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