Comments regarding Proposed Rules in sections 91 and 126 of the Income Tax Act and section 5907 of the Income Tax Regulations in the Consultation Draft of Legislative Proposals related to the Act

In PwC’s submission to the Department of Finance on draft legislation dealing with so-called ‘foreign tax credit generators,’ we maintain that the proposed rules are overly broad and will adversely impact the way many Canadian companies finance and structure their foreign active business operations. PwC recommends that the Department abandon the proposed rules and replace them with a specific anti-avoidance rule that is directed at the abusive types transactions described in the 2010 federal budget documents.

For more details, read our letter to the Department of Finance below.

PwC Finance Submission FTC Generators (1.5 MB) Download the full submission.