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

r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.

Capital v revenue in R&D – isolated concerns or a future battleground? Part one

In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully

Jayne Stokes, June 09 2026

Direct Tax

A&M Tax continues Europe push with Sweden launch

Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax

Sam Sholli, June 08 2026

Direct Tax

Pillar two criticism fair despite filing penalty waiver: BDO tax leader

The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals

Sam Sholli, June 08 2026

Sponsored

Sponsored

Sponsored

Hourglass on financial graphs and reports

Sponsored