Intra-group foreign debt in the Canadian resource industry

March 31, 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 article.

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

To unlock this article:

Take a Free Trial or Login

More from across our site

Saudi arabia flag in the blue sky. Horizontal panoramic banner.

This month in indirect tax: Saudi Arabia’s tax amnesty; Poland v the EU; India’s WTO complaint

Developments included the end of Saudi Arabia’s tax amnesty, Poland’s VAT battle with the EU, the Indirect Tax Forum, India’s WTO complaint, and more.

Euan Healy, June 07, 2023

'HMRC, catch me if you can!'

Charlotte Sallabank and Christy Wilson of Katten UK look at the Premier League's use of 'dual representation' contracts for tax matters.

Charlotte Sallabank, June 06, 2023

Brookfield faces allegations of tax avoidance ahead of AGM

Shareholders are set to vote on whether the asset management firm will adopt public CbCR, amid claims of tax avoidance.

Josh White, June 06, 2023

Analysis: US debt deal could hold back Democratic tax ambitions

US lawmakers averted a default on debt by approving the Fiscal Responsibility Act, but this deal may consolidate the Biden tax reforms rather than undermine them.

Josh White, June 05, 2023

MELBOURNE, AUSTRALIA - JULY 30, 2018: PwC headquarters building

PwC Australia identifies all 67 staff involved in tax scandal

In a letter to the Australian Senate, the firm has provided the names of all 67 staff who received confidential emails but has not released them publicly.

Euan Healy, June 05, 2023

Upper Tribunal hears Ørsted’s windfarm capital allowances appeal

David Pickstone and Anastasia Nourescu of Stewarts review the facts and implications of Ørsted’s appeal at the Upper Tribunal.

David Pickstone, June 02, 2023

This week in tax: IRS set to lose $21bn in funding

The Internal Revenue Service will lose the funding as part of the US debt limit deal, while Amazon UK reaps the benefits of the 130% ‘super-deduction’.

Josh White, June 02, 2023

Gavel of judge with coins against European Union flag

Opinion: EU tax disputes make the case for reform

The European Commission wanted to make an example of US companies like Apple, but its crusade against ‘sweetheart’ tax rulings may be derailed at the CJEU.

Josh White, June 01, 2023

OECD transfer pricing training in West Africa coming to an end

The OECD has announced that a TP training programme is about to conclude in West Africa, a region that has been plagued by mispricing activities for a number of years.

Euan Healy, June 01, 2023