Over the past few years, Canada’s tax landscape has been shaped by significant proposed reforms as well as targeted amendments to address perceived legislative gaps. Among them are a series of technical tweaks and adjustments that, while overshadowed by more high-profile changes, remain highly relevant for international tax practitioners and their clients. These pending amendments may not have grabbed headlines, but are expected to have a meaningful impact.
In this session, our panel will provide a refresher on key proposals that remain in legislative limbo, including updates to the shareholder loan rules (s. 15(2)), the expansion of non-resident withholding tax (s. 212(13.1)), changes to the FAPI tax rate for CCPCs and related surplus adjustments, and amendments to the foreign affiliate reorganization rules.
Join us as we shine a light on these overlooked but important proposals still in play.
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