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Canada: Bumping Foreign Affiliate Shares Under The February 27, 2004 Proposals (Mondaq)
Sat, 11 Feb 2012
February - Canada: Bumping Foreign Affiliate Shares Under The February 27, 2004 Proposals (Mondaq)
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Canada: Bumping Foreign Affiliate Shares Under The February 27, 2004 Proposals (Mondaq)
Sat, 08 Jul 2006 08:21:11 GMT
The February 27, 2004 foreign affiliate proposals present a number of interesting issues for an acquiror of a Canadian target company that owns foreign affiliate shares, particularly where the acquisition is structured to preserve the availability of the tax cost "bump" under paragraphs 88(1)(c) and (d) of the Income Tax Act (Canada) 1 . This article first briefly reviews the limitation in
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