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- Title
Canadian Foreign Affiliate Rules Rules.
- Abstract
The article focuses on the comments submitted by Tax Executives Institute Inc. (TEI) on the consultation by the Canadian Department of Finance for the proposed foreign affiliate legislation released on August 19, 2011. TEI commends the Department for the proposed improvements. TEI highlights the unworkable measures and the impacts of changes including the addition of upstream loans in avoidance techniques, taxation to Related Foreign Entity Finance (RFEF) loans, and the dividend stop-loss rule.
- Subjects
CANADA; TAX Executives Institute Inc.; CANADA. Dept. of Finance; TAXATION of foreign business enterprises; TAX evasion; TAXATION of dividends
- Publication
Tax Executive, 2011, Vol 63, Issue 6, p436
- ISSN
0040-0025
- Publication type
Article