In Print: Foreign Affiliate Update

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This article provides an update on a number of key foreign affiliate technical amendments to the Income Tax Act that the Department of Finance has released. In particular, it covers the proposed amendments to subsection 88(3) with respect to top-tier foreign affiliate distributions, internal transfers and suspension rules proposed in paragraphs 95(2)(c.1) through (c.6), (f.3) through (f.9) and (h) through (h.5), and foreign affiliate mergers, liquidations and distributions proposed in paragraphs 95(2)(d), (d.1), (e), (e.1), (e.3), (e.4) and (e.5).

It covers a number of significant proposals to the foreign affiliate reorganization provisions.


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