Bill C-28, the final 2007 Budget Bill, was enacted on December 14, 2007. In addition to measures implementing aspects of the March 19 2007 federal Budget, Bill C-28 also contained numerous technical amendments to the foreign affiliate rules in the Income Tax Act (Canada) (the ''Act'') that have been outstanding in comfort letter and draft legislation form for many years. These foreign affiliate amendments are effective as of various retroactive dates going back in many cases to taxation years beginning after 1999.
However, Bill C-28 also provides for seven separate one-time elections, including the ''Global Section 95 Election'' (the only one of the elections that may later be revoked), which would allow a taxpayer to apply different packages of these technical amendments to taxation years of foreign affiliates beginning after 1994....
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