I'll combine the next two sets of measures. They deal with foreign affiliate rules. There's a set of currently existing rules in the Income Tax Act that prevents the shifting of income on passive property offshore to a controlled foreign affiliate of a taxpayer. If you have that kind of passive income held in one of your controlled foreign affiliates, it's taxable in Canada on an accrual basis, so every year.
Recent tax planning techniques have evolved to use what are called tracking shares in order to avoid this accrual and taxation of passive income. These measures would prevent the use of tracking shares to avoid the foreign accrual property income regime, both by artificially meeting a five employee test and also through the avoidance of controlled foreign affiliate status itself. These are found in clauses 6 and 7 of the bill.
Also, another foreign affiliate measure relates to the rules for trading or dealing in indebtedness. It essentially aligns the rules for trading or dealing in indebtedness with the rules that relate to investment businesses, to better ensure consistency within the tax regime for foreign affiliates. That is also found in clause 7 of the bill.
The next measure relates to the at-risk rules for limited partnerships. It ensures that the currently existing at-risk rules for limited partnerships apply appropriately in a situation where there is a tiered structure of partnerships—that is to say, where one member of a limited partnership is itself a limited partnership—and it ensures the at-risk rules work appropriately in that situation. The at-risk rules restrict the deduction of losses and expenses by limited partners of a partnership to the amount that they, in effect, put at risk in the partnership. Therefore, if you invest $100, generally speaking, you can deduct up to $100 of losses in respect of the partnership interest. This ensures that the rules work appropriately where there are multiple tiers of partnerships. It is found in clause 8 of the bill.
The next measure relates to tax relief for Canadian Armed Forces personnel and police officers on international police operations. It allows international police missions to be eligible for the purposes of a deduction from income tax that is available for Canadian Armed Forces members deployed on certain designated international missions. It is found in clause 9 of the bill.
The next measure—