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In Print: The Foreign Affiliate Fresh Start Rules
In this In Print issue, PwC’s Jerry Mahnger and Susan McKilligan discuss the background and policy behind the foreign affiliate fresh start rules and review the Advisory Panel on Canada’s System of International Taxation’s proposed amendments to the rules. If the panel’s recommendations are adopted, they will spur greater focus on the characterization of income as foreign accrual property income or active business income, resulting in even more attention on the application of the fresh start rules.
Jerry and Susan highlight some issues concerning the panel’s proposed amendments and recommend changes to help address them. Read the article below to read their suggested modifications.
