التفاصيل البيبلوغرافية
| العنوان: |
EXCLUDED PROPERTY REVISITED. |
| المؤلفون: |
Morin, Cynthia1 |
| المصدر: |
Canadian Tax Journal / Revue Fiscale Canadienne. 2022, Vol. 70 Issue 4, p895-919. 25p. |
| مصطلحات موضوعية: |
*TAXATION, *PROPERTY tax, *BUSINESS tax |
| مستخلص: |
Many tax consequences under the foreign affiliate rules depend on whether a property owned by a foreign affiliate is excluded property; however, the proper application of the excluded property definition can be challenging for taxpayers in practice. More importantly, the application of the excluded property rules can often lead to unfortunate results that are not in line with the policy intent behind those rules--particularly when the relevant property is shares of another foreign affiliate. This article first focuses on challenges that can arise when applying the excluded property definition in practice, especially in the context of tiered ownership structures involving multiple foreign affiliates. Proposed changes to the excluded property rules that address these challenges and achieve results more consistent with the policy objectives of the rules are then considered. [ABSTRACT FROM AUTHOR] |
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