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:
Also in the 2011 Proposals are previously unannounced proposals relating to:
In addition, various other technical amendments are in the package. The Department of Finance has confirmed that these proposals are the final tranche of the updated 2004 Proposals.
The Department of Finance will accept comments relating to the draft legislation and Explanatory Notes until October 19, 2011, and has indicated it will proceed with legislation to implement the amendments at “an early opportunity.”
Learn more in this Tax memo.