New Canadian FA dumping and upstream shareholder loan rules

December 12 2012

In its March 2012 Budget, the Canadian federal government proposed a sweeping and aggressive set of new rules (the FA dumping rules) intended to curtail a practice known as foreign affiliate dumping. A subsequent iteration of the draft rules included a companion relieving rule to allow for upstream shareholder loans in certain circumstances, explain Paul Stepak and Sabrina Wong of Blake, Cassels & Graydon.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025

Direct Tax

Taylor Wessing in merger talks with US firm Winston & Strawn

Taylor Wessing, whose most recent UK revenues were at £283.7m, would become part of a £1.23bn firm post combination

Tom Baker, December 12 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

This week in tax: China adds to growing list of US pillar two carve-out dissenters

China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap

Sam Sholli, December 12 2025

Direct Tax