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).
- 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.
What People Are Saying About Us
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"Excellent training - I found the hands-on practical experience very very useful"
"Very useful and practical courses, the instructor is very knowledgeable. Will definitely recommend to all CPA students"
"The courses were very well structured and organized. Keep up the good work! I'd love to attend more sessions"
"The step by step video tutorial is easy to follow and the case study that required marking and feedback. Overall a Brilliant Course!!"