YIN WEBINAR:A Case Study in Canadian and Select European Controlled Foreign Company/Foreign Affiliate Rules


Tuesday, October 19, 2021

12:00pm-1:00pm Eastern / 9:00am-10:00am Pacific


Webinar / Online Event.

Connection details will be sent to registrants ahead of the event.


Charlotte Haarsma-den Dekker, Loyens & Loeff
Andrew Morreale, Baker McKenzie

Case Study in Canadian and Select European Controlled Foreign Company/Foreign Affiliate Rules

The speakers will explore Controlled Foreign Company (“CFC”) rules, also known as Foreign Affiliate (“FA”) rules under the Canadian Income Tax Act, through case studies using the example of a multinational enterprise with operating and financing structures.

The topics will include the difference of approaches by European countries in implementing the EU’s Anti-Tax Avoidance Directive, as well as Canadian distinctions of active and passive income.

Charlotte Haarsma-den Dekker | Senior Associate, Tax Adviser, Loyens & Loeff

Charlotte Haarsma-den Dekker, senior associate, is a member of the Tax Practice Group in the Luxembourg office. She focuses on advising Luxembourg entities on tax structuring and restructuring. Charlotte advises numerous multinationals and private equity funds on their tax structure in Luxembourg. Her advice relates mainly to private equity, acquisitions, project financing, corporate reorganisations, securitisations and the fund industry. Charlotte was seconded in our London office, where she gained additional in-depth expertise of the UK market. She is a member of the Brexit team and the LegalTech committee of Loyens & Loeff.

Andrew Morreale | Associate, Baker McKenzie

Andrew Morreale is an associate in Baker McKenzie's Tax Practice Group in Toronto. Prior to joining the Firm, Andrew clerked for the judges of the Tax Court of Canada, was a corporate tax instructor at the University of Windsor, Faculty of Law and practiced in the international tax services group at a major accounting firm. Andrew's practice focuses on domestic and cross-border mergers and acquisitions, corporate reorganizations, financing and capital market transactions. Andrew has particular experience advising on outbound structuring and tax treaty issues. He also has expertise in advising underwriters, issuers and investors in respect of flow-through share offerings and investments. Andrew also assists with tax dispute matters, most recently in the context of entitlement to treaty benefits, upstream loans, and the classification of foreign legal instruments.