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Tax Memo: Latest CRA Views on the 95(6)(b) Foreign Affiliate Anti-Avoidance Rule: Reflections
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On July 27, 2007, the Canada Revenue Agency (CRA) released the long-awaited Income Tax Technical News (No.36)(ITTN 36) providing the CRA’s views and “guidance” on the interpretation and application of paragraph 95(6)(b) of the Income Tax Act (the Act). This Tax Memo reflects on whether the ITTN signals a substantive change to previously announced CRA positions.
