In this submission, PwC provides commentary and requests modifications to the proposed amendments to the Income Tax Act's section 261. PwC's submission comments on several matters relating to the Proposals in section 261 including eligibility criteria, application to entities other than corporations, transition rules, determination of amounts payable, anti-avoidance rules, timing of currency translation and other miscellaneous matters. More particularly, PwC comments and makes recommendations on:
This submission reiterates taxpayers' needs for clarity and certainty when applying the tax rules and that without such certainty, the rules would fail to serve the people they were meant to serve. PwC maintains that our comments and recommendations aim to improve the legislation and allow the government to meet its goal of increasing the effectiveness and fairness of the tax system.
|Observations and Issues in respect of Section 261 — Rules Relating to Functional
Currency Reporting (1.43 MB)
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