Taxation of Foreign Affiliates
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The Taxation of Foreign Affiliates relates to the tax consequences under the Income Tax Act and Regulations to a taxable Canadian resident of acquiring, holding and disposing of shares in a non-resident corporation, which is characterized as a foreign affiliate in relation to the taxpayer. The area of the taxation of foreign affiliates is one of the most complex parts of the Canadian tax regime and is becoming increasingly important as Canadian corporations continue to expand their foreign operations.
This supplemented book provides a comprehensive and detailed review of the foreign affiliate rules written in a clear, understandable style. It also includes additional readings references that provide tax practitioners with a summary of what has been written by academics, practitioners and Canada Revenue Agency in the past. The supplemented format of the book ensures that the work is updated to reflect ongoing developments in this area of taxation.
The work includes the following chapters:
• History and General Policy Considerations
• Basic Concepts
• Foreign Accrual Property Income and Income from an Active Business
• Imputation of Foreign Accrual Property Income
• Foreign Affiliate Distributions
• Foreign Affiliate Reorganizations
• Partnerships and the Foreign Affiliate Rules.
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