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Canada: Draft legislation relating to taxation of Canadian banks with foreign affiliates released

Wednesday, 05 March 2014   (0 Comments)
Posted by: Author: Alexander Demner
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Author: Alexander Demner (Thorsteinssons LLP)

The Department of Finance released draft legislative amendments to the Income Tax Act (Canada) and the Income Tax Regulations relating to the taxation of Canadian banks with foreign affiliates. The new proposals contain modifications to those released for consultation on November 27, 2012, and also deal with revisions to the "base erosion” rules in the context of the FAPI regime. The full announcement, with a link to the draft legislative proposals, can be found online at:

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Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.

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