A Consultation Paper - Advisory Panel on Canada's System of International Taxation

Advisory Panel on Canada's System of International Taxation

Contents

1. Introduction

Our Mandate: Enhancing Canada’s International Tax Advantage

The Current Tax Environment

Toward a Tax Policy Framework

Specific Areas for Review

Call for Submissions

2. Taxation of Outbound Direct Investment

Active Business Income of Foreign Affiliates

Foreign Accrual Property Income

3. Taxation of Inbound Direct Investment

Tax Treatment of Interest Expense Incurred by Foreign-owned Canadian Corporations

Inbound Treaty Shopping

4. Withholding Taxes

5. Administrative Issues

6. Consultation Process

Appendix
Selected Reports on International Taxation