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...
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...