The Foreign Affiliate Rules

Authored by Thorsteinssons Lawyers: Bill Holmes and Ian Gamble

This book describes the Canadian income tax rules applicable when a Canadian resident has a direct or indirect interest in shares of a non-resident corporation that is a foreign affiliate. While the purpose of the foreign accrual property income (FAPI) regime and the foreign affiliate regime, can be simply described, the rules number in the hundreds and are immensely complex. In addition there are rules applicable with respect to the disposition of shares of foreign affiliates as well as other matters.

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