Taxation of Foreign Affiliate - a Primer
The course offers a general overview of international outbound tax issues Canadian businesses that operate internationally or are considering expansion outside of Canada. This course includes a review of the foreign affiliate regime (indirect foreign investments).
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Course Description
TOPICS INCLUDE:
- Introduction to Taxation of Foreign Affiliate
- Equity percentage, control and look-through rules
- Active Business and Investment Business
- Foreign Accrual Property Income (FAPI)
- Excluded Property vs. Investment property
- Base Erosion Rules and Income Recharacterization
- Overview of Exempt surplus, taxable surplus, hybrid surplus and pre-acquisition
- Upstream Loans Rules
- Foreign Affiliate Dumping Rules
WHO WILL BENEFIT:
This seminar is designed for Tax professionals who advise corporations on cross-border taxation issues; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director; or work in a government setting that deals with international tax for Canadian businesses.
Course Walkthrough
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General Information
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Presentation Slides & Case Studies
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Taxation of Foreign Affiliate - a Primer
Course Description
TOPICS INCLUDE:
- Introduction to Taxation of Foreign Affiliate
- Equity percentage, control and look-through rules
- Active Business and Investment Business
- Foreign Accrual Property Income (FAPI)
- Excluded Property vs. Investment property
- Base Erosion Rules and Income Recharacterization
- Overview of Exempt surplus, taxable surplus, hybrid surplus and pre-acquisition
- Upstream Loans Rules
- Foreign Affiliate Dumping Rules
WHO WILL BENEFIT:
This seminar is designed for Tax professionals who advise corporations on cross-border taxation issues; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director; or work in a government setting that deals with international tax for Canadian businesses.
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Certificate of Completion
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