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June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules

Author: Geoffrey S. Turner

This article examines the new foreign affiliate reorganization provisions and key elections affecting Canadian corporations with foreign affiliates. It may now be possible for taxpayers to clarify, proactively confirm, or even change the intended tax consequences of historic transactions that closed after December 20, 2002.

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Geoffrey S. Turner
Geoffrey S. Turner

Senior Counsel

416.367.6914

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