New Canadian FA dumping and upstream shareholder loan rules

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

New Canadian FA dumping and upstream shareholder loan rules

December 12, 2012

In its March 2012 Budget, the Canadian federal government proposed a sweeping and aggressive set of new rules (the FA dumping rules) intended to curtail a practice known as foreign affiliate dumping. A subsequent iteration of the draft rules included a companion relieving rule to allow for upstream shareholder loans in certain circumstances, explain Paul Stepak and Sabrina Wong of Blake, Cassels & Graydon.

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
more across site & bottom lb ros

More from across our site

Transfer Pricing
Happy New Year Celebration 2024 Sparkles Banner Generative AI
Editor’s picks: top ITR stories of 2024
ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
Sam Sholli, December 20, 2024
Direct Tax
clifford chance
This week in tax: Tax partner takes top London job at Clifford Chance
Chinwe Odimba-Chapman was announced as Michael Bates’ successor; in other news, a report has found a high level of BEPS compliance among OECD jurisdictions
Sam Sholli, December 20, 2024
Transfer Pricing
OECD image.jpg
OECD releases pricing automation tool for amount B
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
Sam Sholli, December 19, 2024
Transfer Pricing
pillar-one-amount-a-oecd.jpg
US proposes regulations on applying amount B
The rules are intended to implement the substance of an earlier OECD report in its entirety
Sam Sholli, December 19, 2024
Direct Tax
David Helmer and Daren Campbell EY
AI won’t replace the tax professional: EY tech leader
While new technology won’t replace the human touch, it could help relieve companies’ staffing issues, EY’s David Helmer and Daren Campbell tell ITR
Sam Sholli, December 18, 2024
Direct Tax
kpmg.jpg
KPMG outstrips ‘big four’ rivals with 10% tax revenue rise
The firm said the financial growth came from increased demand for its AI services and global tax reform advice
Tom Baker, December 17, 2024
Direct Tax
chrystia freeland.jpg
Canada’s finance minister resigns amid US tariff threat
Chrystia Freeland had also been the figurehead of Canada’s controversial digital services tax adoption, which stoked economic tensions with the US
Tom Baker, December 16, 2024
Direct Tax
flores and bonilla.png
Pillar two not close in Panama or Costa Rica: experts
Panama has no official position on pillar two so far and a move to implement in Costa Rica will face rejection, experts tell ITR
Sam Sholli, December 16, 2024
Direct Tax
suresh perera resized.jpg
‘Setting a precedent’: KPMG’s Perera on his award-winning practice
The KPMG partner tells ITR about Sri Lanka’s complex and evolving tax landscape, setting legal precedents through client work, and his vision for the future of tax
Tom Baker, December 13, 2024
Direct Tax
Irvine, CA, USA - May 6, 2022: Grant Thornton logo is seen at the company's office in Irvine, California. Grant Thornton LLP is a global independent accounting and advisory organization.
This week in tax: Grant Thornton reports 8.9% global tax revenue growth
Overall turnover at the firm also reached a record £8 billion; in other news, Ashurst and Dentons announced senior tax partner hires
Sam Sholli, December 13, 2024
Gift this article