Reforming the Taxation of Foreign Affiliate Share Dispositions: Capital Gains and Surplus Balances

Turner, Geoffrey

doi:10.2139/ssrn.1605270

Abstract

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Reforming the Taxation of Foreign Affiliate Share Dispositions: Capital Gains and Surplus Balances

Geoffrey S. Turner

Davies Ward Phillips & Vineberg LLP

June 10, 2009

Abstract:
The author discusses the recommendation of the Advisory Panel on Canada's System of International Taxation, to exempt from Canadian tax, capital gains realized by Canadian-resident taxpayers from dispositions of top-tier foreign affiliate shares that derive all or substantially all of their value from active business assets.

Number of Pages in PDF File: 5

Keywords: Advisory Panel on Canada's System of International Taxation, foreign affiliates

JEL Classification: H25

working papers series

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Date posted: May 13, 2010

Suggested Citation

Turner, Geoffrey S., Reforming the Taxation of Foreign Affiliate Share Dispositions: Capital Gains and Surplus Balances (June 10, 2009). Available at SSRN: http://ssrn.com/abstract=1605270 or http://dx.doi.org/10.2139/ssrn.1605270

Contact Information

Geoffrey S. Turner (Contact Author)

Davies Ward Phillips & Vineberg LLP ( email )

155 Wellington Street West
Toronto, Ontario M5V 3J7
Canada