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New Canadian FA dumping and upstream shareholder loan rules

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.

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