The Department of Finance (Finance) continues its ambitious agenda. On August 12, 2013, Finance released its Consultation Paper on Treaty Shopping and asked for comments by December 13, 2013. Comments may be submitted by email to Treaty.Shopping-Chalandage.Fiscal@fin.gc.ca. On August 16, 2013, Finance released proposed changes to the so-called foreign affiliate dumping (FAD) rules (http://www.fin.gc.ca/drleg-apl/fa-sea-eng.asp). The existing FAD rules are broadly intended to restrict the ability of foreign-based multinational corporations (MNEs) to transfer (“dump”) foreign affiliates under their Canadian subsidiaries. Finance views such transfers as allowing MNEs to (1) distribute cash from Canada free of withholding tax or (2) leverage their profitable Canadian operations with debt (and deductible interest expense). The existing rules can have surprising implications, some of which are addressed in these latest proposals. Finance asked for comments on its draft legislation by October 15, 2013, which can be sent by email to email@example.com.
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