Finance committee  You've accurately described the difference between the two in result, in that we don't tax and the U.S. will tax with a credit. My hesitation to confirm all of what you have said is that you included an assumption that the income bore underlying foreign tax roughly equal to Canad

Finance committee  In certain cases--an example being our tax shelter reporting requirements--we have an obligation on taxpayers to identify aggressive tax planning structures, or structures they're marketing to the public as producing significant tax benefits. I don't know that disclosure or non-

Finance committee  No, I can't. I don't believe that was the intention of the regulation. Prior to 1994, we did have a rule in our regulations that attempted to say that treaty countries, countries with which Canada had a tax treaty, qualified for exempt surplus treatment. That listing procedure w

Finance committee  It's not a question of evasion; it's a question of legal compliance with the rules.

Finance committee  The question is largely yes, and there are some qualifications to that. Double-dips work best with treaty countries, because the income you generate in the intermediate country is exempt surplus that can be brought home free of tax. From a tax planner's point of view that's the

Finance committee  Thank you for the question. Yes, I hope so. People are projecting a definition onto the term “tax haven”, and it's probably useful to speak to that for a moment. As the backgrounder to our material mentions, you can conceptualize or define a tax haven in at least one of two way

Finance committee  I'm not aware of any connection between us signing the tax treaty and there being a tax haven angle to it. But it was the second point that I wanted to draw out. In addition to simply having low tax rates, one can arrive at having low or no tax through lack of concordance in tw

Finance committee  It would have much different effects from the proposal as currently constituted. It would say that a foreign investment funded with debt in Canada would not be allowed any interest deduction unless and until any income were returned home, and it would--

Finance committee  Subject to these proposals, the current law would in some instances allow a corporation to claim a deduction in Canada and a deduction in another country.

Finance committee  In some situations CRA may be challenging transactions as being too aggressive, and this may reflect on the discussion you had the other day with the agency. But for better or worse, CRA would not seek to challenge under the current law the sort of transaction outlined in the mat

Finance committee  Well, again, I don't believe that's the case.

Finance committee  I'm not sure it is the case that all of a sudden it is legal. I think it has been the case that a borrowing made to invest in shares of a foreign affiliate by a Canadian firm is generally deductible in computing the taxable income and tax payable of a Canadian firm. What you se

Finance committee  I think there are two levels at which to answer the question. In a mechanical, mathematical, or arithmetical analysis, you can't simply look at the value of the interest deduction.... I'm sorry, I should start further back. There are some situations in which other countries wil

Finance committee  Perhaps I'll take on the second part of the question and ask my colleague to speak to the first. On the task force, I expect you're referring to the expert panel that the minister is proposing to set up. There was reference in the budget as well. It's to look at other issues or

Finance committee  Thank you very much for the question. We do not have the numbers today on the dividends being paid out. We saw that you raised this question with the Canada Revenue Agency when they were here last week, and we are trying to find some numbers on that front. We do have some Statis