Tax Insights: Bill C-48 gets royal assent

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Implications for Canadian companies with foreign affiliates

Issue 2013-06

This Tax Insights focuses on foreign affiliate measures in Bill C-48, Technical Tax Amendments Act, 2012, which received royal assent on June 26, 2013. It highlights some important dates.

Taxpayers should review current and completed transactions to determine whether any transitional elections or designations may be required, and to ensure these are filed on time.

Bill C-48 implements measures that were included in a Notice of Ways and Means Motion (NWMM), tabled by Canada’s Department of Finance (Finance) on October 24, 2012.

This comprehensive package of technical income tax legislation implements a variety of outstanding technical tax amendments, including legislative proposals related to the taxation of Canadian multinational corporations with foreign affiliates.

Several foreign affiliate amendments in Bill C-48 (Parts 2 and 3) are the culmination of legislative developments that started almost ten years ago. The bill consolidates and amends foreign affiliate proposals released on:

  • August 27, 2010, which modified proposals released on December 18, 2009
  • August 19, 2011 (referred to as the ‘2011 Proposals’), which modified proposals released on February 27, 2004 (2004 Proposals)