International Tax Newsletter

November 2012

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Introduction

The March 29, 2012 Federal Budget proposed significant changes to Canada’s international tax regime. On October 18, 2012, the Minister of Finance (Canada) introduced Bill C-45 in Parliament to implement these changes.1 This Miller Thomson International Tax Update reviews the...

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Foreign Affiliate Dumping Transactions

John M. Campbell

IN THIS SECTION: Anti-Surplus Stripping Rule for Canadian Resident Corporations Controlled by Non-Residents What Canadian Resident Corporations Are Subject To Section 212.3? What Transactions Are Caught? Canadian Tax Consequences PUC Reduction under Subsection 212.3(7) Dividend Substitution Election PUC Reinstatement More...

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Pertinent Loan or Indebtedness Regime

John M. Campbell

IN THIS SECTION: PLOI Relieving Rule for Subsection 15(2) Shareholder Indebtedness Scope of PLOI Exception PLOI Elections Certain Reorganizations Involving Canadian Resident Corporate Creditors Deemed Interest Income To File or Not to File a PLOI Election? Application Date PLOI Relieving...

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Thin Capitalization Regime

John M. Campbell

IN THIS SECTION: Existing Canadian Thin Cap Regime Proposed Amendments to the Canadian Thin Cap Regime Reduction of Debt-to-Equity Ratio Extension of Canadian Thin Cap Regime to Loans from Specified Non-Residents to Partnerships Deemed Dividend Treatment for Canco’s Non-Deductible Interest...

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Displaying 1-4 of 4