Canada’s Dept of Finance released draft legislative proposals, with comments due by 7 October 2019.
Canada has complex rules re: foreign affiliate dumping, etc. making it more complex to place subsidiaries under a Canadian holding company without proper planning for Paid Up Capital and other items, and these proposals appear to tighten those rules.
Cross border securities lending arrangements are included re: additional rules.
Tax professionals with Canadian operations should monitor this legislation accordingly.
EY’s Global Tax Alert provides additional details therein.