Canadian investors and the Canadian investment industry will be interested in recent comments by Finance on the tracking arrangement rules.
Canadian investors and the Canadian investment industry will be interested in recent comments by Finance on the tracking arrangement rules. Finance has recognized industry concerns that the tracking arrangement rules, in some certain circumstances, should not cause the foreign affiliate regime to apply to investments in foreign investment funds, and indicated that it is prepared to recommend amendments to these rules. Specifically, Finance notes that it intends to recommend changes so that a non-resident corporation will not be considered a controlled foreign affiliate of a taxpayer in certain circumstances under subsection 95(11) or 95(12) of the Act.
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