The Department of Finance recently released a 200 page package of draft foreign affiliate amendments. The package includes revisions to the foreign affiliate reorganization and distribution rules originally proposed in a February 27, 2004 release. It also includes new proposals in place of the 2004 proposals which suspended certain gains from the sale of shares and other assets of foreign affiliates for the purposes of the surplus accounting rules. In addition, a number of altogether new rules have been proposed that have potentially significant implications, such as those regarding upstream loans from foreign affiliates, foreign currency gain and loss recognition and the computation of foreign accrual property income.
On Wednesday, August 31st, 2011, KPMG’s senior professionals from our International Corporate Tax team hosted a webcast that discussed what your tax department needs to know to tax-effectively structure and manage your company’s foreign affiliate-related obligations under Canada’s existing and proposed foreign affiliate rules.
If you were unable to join the webcast, an archived version of it and a copy of the presentation are now available for access at any time. To download a copy of this presentation, please click here. [PDF 676Kb]
Please note that you need to register to view the webcast replay and download the presentation.