When Do the Stop-Loss Rules Apply? Transactions Involving Foreign Affiliates After the 2012 Technical Bill

Jim Samuel ()
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Jim Samuel: KPMG Canada, Calgary

Canadian Tax Journal, 2016, vol. 64, issue 3, 561-600

Abstract: Bill C-48, the Technical Tax Amendments Act, 2012, ushered in a new era of stop-loss rules in the context of transactions involving foreign affiliates. Building on the basic concepts discussed in an earlier article by the same author, this article explores subsequent developments in the stop-loss realm--in particular, the significant stop-loss-related changes that were included in the 2012 technical bill.

Keywords: Stop-loss rules; foreign affiliates; foreign exchange; surplus; FAPI; loans (search for similar items in EconPapers)
Date: 2016
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