eprivateclient took a quick look at what’s happened in North America…
In Canada, withholding tax may soon be applied to companies controlled by non-resident trusts. The consultation closes on 7 October on the Department of Finance Canada's proposed legislation to broaden the foreign affiliate dumping rules to catch individuals, trusts and estates, as well as Canada-resident corporations controlled by non-resident corporations.
The new rules would impose non-resident withholding tax on constructive upstream dividends where controlling interests in the corporation are owned by individual...