Intra-group foreign debt in the Canadian resource industry

March 01 2012

The Department of Finance recently released proposed amendments to Canada’s foreign affiliate regime including rules dealing with so-called upstream loans. Bruce Sinclair and Kirsten Kjellander of Blake, Cassels & Graydon explore implications of these proposals for multinational enterprises involved in the natural resource industry.

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

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

David Beringer, Sucafina, ITR P2 Forum 2026.JPG

Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

Unity Advisory appoints AI chief as firm hits 100 employees

The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’

Sam Sholli, April 27 2026

Direct Tax

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

A taxing week: Brazil’s pillar two carve-out request prolongs a death by a thousand cuts

Projected revenue losses and exemption requests are harming the project’s capability and viability

Sam Sholli, April 24 2026

Indirect Tax

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

Tom Baker, April 24 2026

Transfer Pricing

‘More refined’: advisers dissect updated ATO TP guidance

Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined

Sam Sholli, April 23 2026

Direct Tax

AI in tax: from early promise to everyday reality

ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London

April 22 2026

Direct Tax

Brazil has ‘substantive grounds’ for pillar two carve-out request: advisers

Brazil’s bid to seek US-style exemptions from pillar two is ‘highly advantageous’ for multinationals, ITR has also heard

Sam Sholli, April 22 2026