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 2026

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

Cookies Settings

Intra-group foreign debt in the Canadian resource industry

March 31 2012
canada.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

NewsCanadaIndirect Tax
more across site & shared bottom lb ros

More from across our site

What Corporates Want 2026 use of technology article header
A taxing week: The technology arms race is being judged by clients – not firms
ITR’s survey data reveals widespread client disappointment with firms’ use of technology but our upcoming AI in Tax event offers advisers a chance to flip the script
Tom Baker, April 17 2026
Direct Tax
London
This week in tax: Vinson & Elkins hires Kirkland tax partner in London
Firms announced key tax partner hires across the US and UK, while fintech and software providers revealed board appointments and new tools for multinational tax teams
Sam Sholli, April 17 2026
Direct Tax
Stuttgart, Germany - 06-19-2022: Cellphone with logo of American consulting company Alvarez and Marsal LLC on screen in front of website. Focus on center-right of phone display.
A&M Tax launches in Ireland with EY, DLA Piper hires
It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Sam Sholli, April 16 2026
Transfer Pricing
india.jpg
‘Taxpayers are thrilled’: local experts hail record-breaking Indian APAs
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Sam Sholli, April 16 2026
Direct Tax
merger.jpg
Hogan Lovells Cadwalader merger approved, debut planned for July
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
Noemi Distefano, April 15 2026
Podcasts
Editable TT 640x360 article-thumbnail (4).png
Podcast: Side-by-side or upside down? Analysing the future of pillar two
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Tom Baker, April 15 2026
Direct Tax
Gulf Cooperation Council GCC
Rethinking permanent establishment in the GCC after pillar two
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Hany Elnaggar, April 14 2026
Direct Tax
Merger international
Ashurst Perkins Coie moves forward with partners’ vote
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
Noemi Distefano, April 13 2026
Transfer Pricing
norton rose fulbright
Norton Rose Fulbright hires new TP head from Baker McKenzie
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
Sam Sholli, April 13 2026
Direct Tax
Heggs_Kara.jpg
Newly-promoted Skadden UK partner talks TP, growth areas and HMRC collaboration
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
Sam Sholli, April 13 2026
Gift this article