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...
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...
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...
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...