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Inside Internal Controls

News and discussion on implementing risk management

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foreign merger

Proposed foreign merger rollovers rules: Welcome news to foreign companies that cannot rely on existing tax treaty rollover provisions

On October 27, 2017, under Bill C-63, the Department of Finance released proposed amendments to the Income Tax Act (Canada) (“ITA”) introducing a new elective rule allowing non-residents tax-deferred rollover treatment on dispositions of certain taxable Canadian property (“TCP”) in a foreign merger.


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