New Canadian FA dumping and upstream shareholder loan rules

December 12 2012

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.

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

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Welcome change ahead for UK tax adviser requirements

HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation

Sam Sholli, May 15 2026

Direct Tax

This week in tax: Greenberg Traurig loses case over faulty tax advice to Dutch DJ

Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires

Sam Sholli, May 15 2026

Transfer Pricing

‘TP not a mechanical compliance exercise’: experts dissect Brazil’s Petrobras ruling

The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR

Sam Sholli, May 14 2026

Podcasts

Taxing Times podcast Jeff Soar WTS article header

Podcast: WTS UK’s CEO breaks cover on strategy, the big four and AI

Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI

Tom Baker, May 14 2026

Direct Tax

Charles Russell appoints partner to build Italian corporate tax practice

The move reinforces Milan’s role as a key European hub for international business, the firm said

Sam Sholli, May 13 2026

Direct Tax

ATO to receive A$86.3m funding over four years

Australia’s government has also announced that it will implement the pillar two side-by-side agreement

Sam Sholli, May 13 2026

Direct Tax

Exclusive: Fieldfisher private client specialist leaves for barrister-led practice

Sara Morgan is due to join Joseph Hage Aaronson & Bremen as a partner in London, ITR understands

Tom Baker, May 11 2026

Direct Tax

‘No one’s eating anyone else’s lunch’: inside McDermott’s tax-powered merger

The newly combined tax team has already worked on thousands of joint client matters, leaders from McDermott Will & Schulte tell ITR

Tom Baker, May 11 2026

A taxing week: 2026 is the watershed year for AI in tax

As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate

Tom Baker, May 08 2026

Direct Tax

The globe, with lines connecting different countries

This week in tax: US and Swiss MNEs lag global counterparts on CbCR compliance

New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities

Tom Baker, May 08 2026