Intra-group foreign debt in the Canadian resource industry

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Intra-group foreign debt in the Canadian resource industry

March 01 2012
intra-puff2.jpg

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

FeatureITR MagazineMarch 2012
more across site & shared bottom lb ros

More from across our site

Transfer Pricing
Suited figure pointing to audit among various hexagonal icons
Why South Africa’s tax audits are becoming unforgiving
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
Akashni Ashok Latchanna, November 12 2025
Direct Tax
Baker McKenzie
Baker McKenzie appoints ex-IRS senior attorney to US tax practice
The hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
Sam Sholli, November 11 2025
Direct Tax
james jobson and matthew missaghi.png
‘Big four but without the crap’: inside WTS Australia’s ambitions
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
Tom Baker, November 10 2025
Rankings analysis
2027 world tax research webinar
ITR World Tax 2027 webinar: completing your submission
Join ITR's Head of Research, John Harrison, for an overview of key dates, new developments, best practices, and more for next year’s research cycle
November 10 2025
Direct Tax
1024px-Donald_Trump_(53911666084).jpg
A taxing week: Supreme Court tariff loss would spell disaster for Donald Trump
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
Sam Sholli, November 07 2025
Direct Tax
Background of 100 dollar bills
This week in tax: US public CbCR opposition caused $475bn tax loss, report claims
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Sam Sholli, November 07 2025
Transfer Pricing
UN large
UN TP database proposal is flawed, experts argue
Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
Sam Sholli, November 06 2025
Transfer Pricing
Business process management and workflow automation diagram with
Templates to tuning: how multi-model databases are reshaping TP automation
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
Sahasranshu Dash , November 06 2025
Indirect Tax
President Trump
This month in indirect tax: Trump’s Supreme Court tariff showdown begins
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Sam Sholli, November 05 2025
Transfer Pricing
peter kiraly resized.jpg
ITR Award Winner Series: Péter Király, DLA Piper Hungary
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
November 05 2025
Gift this article