Notice of Ways and Means Motion October 2018 – Cross-Border Surplus Stripping Using Partnerships and Trusts
Cross-Border Surplus Stripping Using Partnerships and Trusts Budget 2018 The Income Tax Act contains a rule (section 212.1) that is intended to prevent a non-resident shareholder from entering into transactions to extract free of tax (or “strip”) a Canadian corporation’s surplus in excess of the PUC of its shares, or to artificially increase the […]