Long-awaited foreign affiliate amendments released


On August 19, 2011, the Honourable Jim Flaherty, Minister of Finance, released a package of legislative proposals relating to the taxation of Canadian multinational corporations with foreign affiliates.

Included in this long-awaited package are significant revisions to the proposals previously released on February 27, 2004 and subsequently addressed in various comfort letters relating to:

  • the sale of shares of foreign affiliates,
  • the reorganization of foreign affiliates,
  • distributions from foreign affiliates.

Topics to addressed in this webcast include:

  • hybrid surplus,
  • upstream loans,
  • foreign affiliate reorganizations,
  • return of adjusted cost basis,
  • surplus anti-avoidance rules,
  • stop-loss rules,
  • FAPI loss streaming,
  • surplus calculations.