On 27 February 2014, the Department of Finance released draft legislative proposals relating to the Canadian Income Tax Act and Income Tax Regulations concerning the taxation of Canadian banks with foreign affiliates.
The proposals contain modifications to the draft legislation released for consultation on 27 November 2012 (announced in Budget 2012) in respect of the "base erosion" rules in the Income Tax Act's foreign accrual property income regime.
The modifications, among other things: