Intra-group foreign debt in the Canadian resource industry

March 01, 2012

The Department of Finance recently released proposed amendments to Canada’s foreign affiliate regime including rules dealing with so-called upstream loans. Bruce Sinclair and Kirsten Kjellander of Blake, Cassels & Graydon explore implications of these proposals for multinational enterprises involved in the natural resource industry.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & bottom lb ros

More from across our site

Direct Tax

Co-sourcing in tax: a growing trend with pillar two

In-house teams who want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues

Russell Gammon, January 22, 2025

Direct Tax

Trump: OECD’s pillar two ‘no force or effect’ in US

The OECD has vowed to continue working with the US despite the president effectively pulling the country out of the organisation’s global minimum tax deal

Sam Sholli, January 21, 2025

Direct Tax

Exploring the tax classification of non-Dutch entities in 2025

Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies

Bart Le Blanc , January 20, 2025

Direct Tax