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Taxation of Foreign Affiliates
By: Angelo Nikolakakis, LL.B., B.C.L.
Availability: Temporarily out of stock
The Taxation of Foreign Affiliates relates to the tax consequences under the Income Tax Act and Regulations to a taxable Canadian resident of acquiring, holding and disposing of shares in a non-resident corporation, which is characterized as a foreign affiliate in relation to the taxpayer. The area of the taxation of foreign affiliates is one of the most complex parts of the Canadian tax regime and is becoming increasingly important as Canadian corporations continue to expand their foreign operations. This supplemented book provides a comprehensive and detailed review of the foreign affiliate rules written in a clear, understandable style. It also includes additional readings references that provide tax practitioners with a summary of what has been written by academics, practitioners and Canada Revenue Agency in the past. The supplemented format of the book ensures that the work is updated to reflect ongoing developments in this area of taxation. The work includes the following chapters: • History and General Policy Considerations • Basic Concepts • Foreign Accrual Property Income and Income from an Active Business • Imputation of Foreign Accrual Property Income • Foreign Affiliate Distributions • Foreign Affiliate Reorganizations • Partnerships and the Foreign Affiliate Rules.
About the Author
Angelo Nikolakakis, LL.B., B.C.L., is a partner in the Montreal office of Couzin Taylor LLP, and a limited partner of Ernst & Young LP, which provides services to Ernst & Young LLP, specializing in corporate and international tax law. His focus is primarily on domestic and international corporate transactions, including mergers, acquisitions, reorganizations, divestitures, inbound and outbound multinational direct investment, and structured financing. Mr. Nikolakakis is a frequent speaker and writer on various topics of corporate and international tax law, including at conferences organized by the Canadian Tax Foundation, the American Bar Association, the International Bar Association, the International Fiscal Association, Federated Press and the Strategy Institute. He has been published in Tax Planning International Review, International Tax Review, Corporate Finance, Corporate Groups and Structures, the Journal of International Trust and Corporate Planning, as well as in publications released by the preceding organizations. Mr. Nikolakakis is a sessional lecturer at the Faculty of Law, McGill University, where he has given courses on Tax Policy and on International Taxation. Before joining Couzin Taylor LLP and the E&Y organization, he practised with Davies Ward Phillips & Vineberg LLP and previously with Stikeman Elliott LLP.