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On December 10, 2008 the Report (the "Report") of the Advisory Panel on Canada's System of International Taxation (the "Panel") was released. It is fair to say that the Report is balanced, practical and reasonable.

Background

The creation of the Panel was announced in May of 2007 in response to a fire-storm of criticism from business and tax professionals of an ill-conceived proposal included in the 2007 Federal Budget of Minister of Finance Jim Flaherty to significantly restrict the deductibility for Canadian tax purposes of interest on funds borrowed by a Canadian corporation to finance a "foreign affiliate", and as part of the Minister's rapid back-pedaling from that proposal. This proposal was a good example of how tax policy should not be made....

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