• Canada Interprets Anti-Hybrid Rules in Treaty with the U.S.
  • March 24, 2010 | Author: Stephanie A. Wong
  • Law Firm: Borden Ladner Gervais LLP - Toronto Office
  • The Canada Revenue Agency (“CRA”) recently provided its views on the application by Canada of its domestic rules to certain planning which has been proposed to avoid the application of the anti-hybrid rules in the Canada-U.S. Income Tax Convention (the “Treaty). The CRA has also released an internal document which sets out its views on the application of the “same treatment” test under these rules.