Global

Details

  • Service: Tax, International Corporate Tax, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 8/22/2012

Canada - New shareholder loan elective imputed interest benefit 

August 22:   Canada’s Department of Finance has proposed changes to the shareholder loan rules in subsection 15(2) in its draft legislation released on 14 August 2012.

These proposed changes would allow an elective imputation of interest on a "pertinent loan or indebtedness" that would otherwise have given rise to a deemed dividend.


This new concept of a "pertinent loan or indebtedness" would also apply to loans that may have otherwise been subject to the foreign affiliate dumping rules.


Read an August 2012 report prepared by the KPMG member firm in Canada:
New Shareholder Loan Elective Imputed Interest Benefit




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