Taxation of Foreign Affiliate - a Primer

The course offers a general overview of international outbound tax issues Canadian businesses that operate internationally or are considering expansion outside of Canada. This course includes a review of foreign affiliate regime (indirect foreign investments).

22 May 2020, 9:00 AM

1.5 CPD hours


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Course Description


  • Introduction to Taxation of Foreign Affiliate
  • Equity percentage, control and look-through rules
  • Active Business and Investment Business
  • Foreign Accrual Property Income (FAPI)
  • Excluded Property vs. Investment property
  • Base Erosion Rules and Income Recharacterization
  • Overview of Exempt surplus, taxable surplus, hybrid surplus and pre-acquisition
  • Upstream Loans Rules
  • Foreign Affiliate Dumping Rules


This seminar is designed for Tax professionals who advise corporations on cross-border taxation issues; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director; or work in a government setting that deals with international tax for Canadian businesses.

Course Walkthrough

  • Presentation
  • Recording
  • Certificate: Taxation of Foreign Affiliate - a Primer
  • Feedback / comments

About the Instructor(s)

Picture of Affan Khalid
Affan Khalid

Affan Khalid, CPA, CA is a Senior Manager in International Tax at MNP LLP. He has over 15 years of experience and provides international tax advice to Canadian and foreign-based multi-nationals with a focus on inbound and outbound tax planning and structuring, including financing structures, acquisitions and dispositions, tax due diligence, reorganizations and cash repatriation strategies. He obtained his BBA from the University of Toronto and have completed In-depth International course and In-depth tax program.

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