Tax Memo: Bill C-28 Foreign Affiliate Elections — Approaching Filing Deadline

Companies with foreign affiliates could be affected by a number of generally relieving technical amendments to the foreign affiliate rules that became effective after Bill C-28 received royal assent on December 14, 2007. While most of the amendments apply retroactively, a Canadian taxpayer can elect to extend the benefit of certain provisions to even earlier taxation years. These elections are due June 30, 2008, for taxpayers with 2007 calendar taxation years. Elections that are not filed on time might not be accepted, which could have various surplus and foreign accrual property income (FAPI) implications for the Canadian taxpayer.

Tax Memo: Bill C-28 Foreign Affiliate Elections — Approaching Filing Deadline (58 KB) Download the full PDF Tax Memo.