Tuesday, October 19, 2021
12:00pm-1:00pm Eastern / 9:00am-10:00am Pacific
Charlotte Haarsma-den Dekker, Loyens & Loeff
Andrew Morreale, Baker McKenzie
Case Study in Canadian and Select European Controlled Foreign Company/Foreign Affiliate Rules
The speakers will explore Controlled Foreign Company (“CFC”) rules, also known as Foreign Affiliate (“FA”) rules under the Canadian Income Tax Act, through case studies using the example of a multinational enterprise with operating and financing structures.
The topics will include the difference of approaches by European countries in implementing the EU’s Anti-Tax Avoidance Directive, as well as Canadian distinctions of active and passive income.
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