International Taxation - Canadian Tax Foundation

Transcription

Shawn Brade, CA
KPMG LLP
Calgary Young Practitioners Group
International Taxation
Outbound Investment – Overview & Update
I.
Foreign Affiliate / Controlled Foreign Affiliate
•
FAPI Overview
•
Surplus Overview
•
October 24, 2012 NWMM
•
•
Foreign Affiliate Distributions
•
Upstream Loans
•
Foreign Tax Credit (“FTC”) Generators
Inbound Investment Update
II.
•
•
2
Foreign Affiliate Debt Dumping
Thin Cap Changes
Shawn Brade, CA
Outbound Investment
– Overview & Update
3
Shawn Brade, CA
Foreign Affiliate Legislation
Japan
4
Karaoke
Alcohol
Shawn Brade, CA
Foreign Affiliate Legislation
FAPI
5
Surplus
Shawn Brade, CA
Outbound Investment

6
Foreign Affiliate vs. Controlled Foreign Affiliate
Shawn Brade, CA
Definition of Foreign
Affiliate
 Contained
in subsection 95(1)
 Generally,
taxpayer must hold at least 1% of
shares, and taxpayer and related persons
must hold at least 10% of shares
 Surplus
rules apply. FAPI rules do not,
although amounts included in taxable
surplus.
7
Shawn Brade, CA
Definition of Controlled
Foreign Affiliate
 Non-resident corporation must first be a FA
 FA will be a CFA of a taxpayer resident in Canada (“Canco”) if
FA is controlled by either
(a)
The taxpayer (i.e., Canco)
(b) Persons that are related to Canco
(c)
Canco and not more than 4 other persons resident in Canada
(“relevant Canadian shareholders”)
(d) Persons who do not deal @ arm’s length with any relevant
Canadian shareholder
 FAPI earned by a CFA is subject to Canadian taxation on a
current basis.
8
Shawn Brade, CA
Foreign Affiliate
Canco
Is Forco a CFA of Canco?
 Forco is controlled by Canco therefore
under (a), Forco is a CFA of Canco
> 50%
Forco
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Shawn Brade, CA
Foreign Affiliate
Canco
1%
Cansub
99%
Forco
 Forco is controlled by persons that are related to Canco therefore
under (b), Forco is a CFA of Canco
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Shawn Brade, CA
Foreign Affiliate
Canco
Cansub
0.9%
99.1%
Forco
 Similar to previous slide, Forco is controlled by persons that are
related to Canco
 However, Forco is not a foreign affiliate of Canco. Therefore , Forco
cannot be a CFA of Canco
11
Shawn Brade, CA
Foreign Affiliate
Canco
40%
Mrs.
Smith
Mr. Smith
40%
20%
Forco
 Forco is controlled by Canco and not more than 4 other persons
resident in Canada therefore under (c), Forco is a CFA of Canco
12
Shawn Brade, CA
Outbound Investment

Foreign Accrual Property Income (“FAPI”)
13
Shawn Brade, CA
You Won’t be Happy if You
Have FAPI!
 Overall objective of FAPI rules
14

To ensure that Canadian corporations pay tax annually on income
from investments that are located in an off-shore jurisdiction but
that remain under the control of the Canadian corporation

Without these annual accrual rules, Canadian tax on the income
could be deferred indefinitely, or at least until the income was
remitted to back to Canada
Shawn Brade, CA
FAPI Overview
 FAPI earned by a CFA is taxable to a Canadian resident
shareholder on an accrual basis

FAPI earned by a FA is also added to taxable surplus
 Inclusion of FAPI in computing a Canadian taxpayer’s income
is based on “participating percentage”
 Deduction available for foreign accrual tax (“FAT”) * relevant
tax factor
 FAPI computed under Canadian tax rules

In Canadian dollars unless Canadian shareholder has made a
functional currency election
 FAPI is usually, but not always, comprised of passive income
earned by the CFA
15
Shawn Brade, CA
Subsection 91(1) –
Foreign Accrual Property
Income
s.91(1) $1,000
Canco
100%
CFA
$1,000 3rd Party
interest income
$100 foreign taxes
(10%)
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 In computing the income of a taxpayer
resident in Canada there shall be included
 In respect of each share owned by the
taxpayer of the capital stock of a
controlled foreign affiliate
 The percentage of the foreign accrual
property income of any controlled foreign
affiliate of the taxpayer
 For each taxation year of the affiliate
ending in the taxation year of the taxpayer
 Equal to that share’s participating
percentage
Shawn Brade, CA
Subsection 91(4) –
Amounts Deductible for
Foreign Taxes
s.91(1)
$1,000
s.91(4)
(400)
T/I
600
Tax Rate
25%
Cdn Taxes $150
Canco
CFA
 Where an amount has been included in
income under subsection 91(1) in the
current year or any of the 5 preceding
years
 There may be deducted the foreign
accrual tax applicable to the amount
included in income multiplied by the
relevant tax factor
$1,000 3rd Party
interest income
$100 foreign taxes
(10%)
17
Shawn Brade, CA
Relevant Tax Factor
 Defined is subsection 95(1)
 Currently defined as

1/ 38% or 2.63 for corporations

2 for individuals
 Used as a mechanism to gross up income in order to take into
consideration Canada’s effective tax rate
 Due to the decreases in Canada’s tax rates over the past few
years, the RTF is proposed to be adjusted to

18
1/ (38% - 13%) or 4.00 for corporations
Shawn Brade, CA
FAPI Example – Year 1
Year 1 – Income Inclusion
Canco
Canco’s share:
Forco EBT
$60,000
Taxes paid
6,000
Net income $54,000
60%
Forco
Forco EBT
Taxes paid
Net income
FAPI inclusion under s.91(1)
$60,000
Deduction under 91(4)
$6,000 x RTF of 2.4
(24,000)
Taxable income
$36,000
Canadian tax @ 25%
$100,000
10,000
$ 90,000
$9,000
Year 1 - Addition to ACB
Addition to ACB under s.92
$60,000
Deduction from ACB under s.92 $24,000
Total
19
$36,000
Shawn Brade, CA
FAPI Example – Year 2
Year 2
Canco
60%
Forco1
Dividend paid = $50,000
20
Canco’s share of
dividend = $30,000
Dividend income under s.90
$30,000
Deduction under s.113(1)(b)
$3,000 x (RTF – 1) or 3
(9,000)
Net balance
21,000
Deduction under s.91(5)
(21,000)*
Taxable Income
$
0
* Deduction is limited to lesser of net balance
and net adjustments to ACB of shares under
s.92
Shawn Brade, CA
Outbound Investment

Surplus Overview
21
Shawn Brade, CA
Section 90 – Dividends
Received From
Non-resident Corporation
Section 90 income inclusion:
Canco
Dividend from
IBM shares =
$1,000
Dividend
from FA =
$1,000
FA
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Dividend from IBM
Dividend from FA
Net income
$ 1,000
1,000
2,000
Potential s.113 deduction
re FA dividend
(1,000)
Taxable income
$ 1,000
Shawn Brade, CA
FA Investment – The Details
What is surplus?
 Essentially determines the Canadian taxability of dividends paid by foreign
affiliates to a Canadian corporation
 Four Categories:
Exempt Surplus
•
•
•
Includes certain capital gains
Hybrid Surplus (proposed)
•
•
Represents 50% exempt surplus and 50% taxable surplus
•
Would generally include capital gains arising from the sale of shares of a foreign
affiliate
Taxable Surplus
•
•
Represents earnings from an active business carried on in a non-designated
treaty country / non-TIEA
•
Includes passive earnings from a designated or non-designated treaty country
and certain capital gains
Pre-acquisition Surplus
•
•
23
Represents earnings from an active business carried on in a designated treaty
country / TIEA
Investment in the affiliate
Shawn Brade, CA
Dividend Payments
 First paid out of Exempt Surplus (ES), then out of Taxable Surplus (TS) & then out
of Pre-acquisition Surplus (PS)
•
If hybrid surplus rules enacted, order would be: ES, HS, TS, PS with certain elections
available to modify the order
 In general, PS is essentially the ACB of the shares
 S.90 - Dividend included in income
 S.113(1)(a) - Deduction equal to dividend paid from ES
 S.113(1)(a.1) – Deduction for one ½ of HS dividend plus grossed up deduction for
foreign income tax paid on other ½
 S. 113(1)(b) - Grossed up deduction for foreign income tax paid on TS dividend
 S. 113(1)(c) - Grossed up deduction for foreign WHT paid on TS dividend
 S. 113(1)(d) - Equal deduction for PS dividend but reduces ACB
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Shawn Brade, CA
Dividend Example
Income calculation
90 – Income inclusion
Canco
($100)
113(1)(b) – ‘Grossed up’ tax on TS dividend
($ 30)
113(1)(d) – PS dividend
($ 100)
113(1)(c) – ‘Grossed up’ WHT on TS dividend
Dividend $300
$
Canadian Tax Payable
$ 12.5
Total Tax Paid on “Taxable Surplus”
FA
$ 10
WHT
$
Total tax
Canadian tax would otherwise have been:
TS = $100
UFT = $10
Taxable surplus-earnings before tax)
Canadian tax rate
Total tax
25
50
25%
Foreign
Canadian
ES = $100
($ 20)
Income taxable in Canada
Tax Rate
WHT = 5%
$ 300
113(1)(a) –ES dividend
5
$12.5
$27.5
$110
25.0%
$27.5
Shawn Brade, CA
93(1) Election
 Disposition of shares of a FA by Canco is a taxable event
 Proceeds – ACB = Capital Gain
 Undistributed profits could be reason that proceeds > ACB
 93(1) election allows taxpayer to treat proceeds received on the sale of an
FA’s shares as a dividend
 Effect of election is to reduce capital gain that would otherwise arise on the
sale
•
ES – no tax on these proceeds
•
HS - no tax if foreign tax paid on profits is sufficient
•
TS – no tax if foreign tax paid on profits is sufficient
 93(1) election does not require actual payment of dividend
26
•
Should be no WHT in foreign jurisdiction
•
Gain may still be taxable in the country of residence of the FA
Shawn Brade, CA
93(1) Election - Example
Canco
Forco
FMV = $100
ES = $30
ACB = $50
 Disposition of Forco would result in a capital gain of $50 ($100 - $50)
 93(1) election filed to reduce proceeds by $30
 Result
•
Capital gain reduced to $20 ($70 reduced proceeds - $50 ACB)
•
Deemed dividend income inclusion of $30
•
Deduction for ES dividend of $30
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Shawn Brade, CA
External Sale of FA Shares:
Application of Section 93
 Assume that FA1 is selling its shares of FA2 to a
third party
Canco
FA1
 Subsection 93(1.1) automatically applies to deem
Canco to have made a s.93(1) election
HS = $400
TS = $200
FMV = $900
ACB = $300
FA2
 Elected amount is equal to lesser of (i) capital
gain otherwise realized ($600), and (ii) dividends
that would be received if FA paid out its net
surplus ($200)
Proceeds on sale
Automatic ‘election’ under s.93(1.1)
Revised proceeds
ACB of shares
Capital gain
$900
(200)
700
(300)
$400
TS = $200
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Shawn Brade, CA
Foreign Holdco Example
Canco
Canco
Forco
Holdco
Canada
Foreign
Forco
 Gain on disposition of Forco would be immediately taxable in Canada
 Gain on disposition of Forco by Holdco
•
Holdco is normally in a jurisdiction that does not tax gains
•
If Forco shares are excluded property, no CDN tax (i.e., no FAPI)
•
Proceeds redeployed to other foreign businesses
•
Holdco as a ‘mixer’
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Shawn Brade, CA
Outbound Investment
Overview and Update

30
October 24, 2012 NWMM
Shawn Brade, CA
Status of Foreign Affiliate
Rules
 October 24, 2012 package includes
August 19, 2011 draft legislation
•
•
•
Introduction of Hybrid Surplus and Upstream Loans
August 27, 2010 draft legislation
•
•
•
•
•
•
31
Significant changes to numerous FA provisions
Non-resident trust rules
Foreign tax credit generator rules
Bump and surplus computations on acquisitions of control
FAPL carry-over periods
Foreign affiliate deficit re-allocations
Shawn Brade, CA
Foreign Affiliate
Distributions
 All pro-rata distributions treated as dividends regardless of
foreign treatment
•
Non pro-rata distributions treated as shareholder benefits
 New election allows distributions to be treated as “qualifying
returns of capital” to extent of FA’s paid-up capital
•
Non-corporate taxpayers have ability to access cost base of
shares
 Revised election allows distributions to be treated as preacquisition surplus dividends if otherwise exempt, taxable,
hybrid surplus dividends
•
•
•
32
Election previously only available for dividends paid to Canada –
can now elect pre-acquisition treatment between FAs
Applies to dividends paid after August 19, 2011, but can elect
retroactively back to December 2002
New rules allow election to be late-filed up to 10 years if “just
and equitable”
Shawn Brade, CA
Upstream Loans – The
General Idea
Prior to August 19, 2011 draft
legislation - Loans of taxable
surplus by foreign affiliates back
to Canada have generally
occurred if payment of dividend
Canco
Loan
$500

FA1
POD
ACB
Gain
FA2
33
$1,000
0
$1,000
ES $500


not permitted under foreign
corporate or other law
triggers foreign withholding
tax
triggers Part I tax in Canada
TS $500
UFT 0
Shawn Brade, CA
Upstream Loans Refresher
 Rules apply to loans made by a foreign affiliate (Lender FA) or
by a partnership in which a FA is member to a “specified debtor”

Canadian taxpayer, non-arm’s length persons, certain partnerships

Excludes controlled foreign affiliates but only if controlled by
Canadians
Canco
NR
NR
Parent
Canco
Canco
Lender
FA
Lender
FA
Parent
Lender
FA
34
Debtor
FA
Shawn Brade, CA
Upstream Loans Refresher
 Loans excluded from rules if

Repaid within 2 years from date loan made

Made in ordinary course of creditor’s business and arrangements
made for repayment within reasonable period of time
 If loan included in income, deductions available for exempt
surplus, hybrid surplus, taxable surplus of Lender FA
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Shawn Brade, CA
Upstream Loans – Changes
to Rules
 Additional deductions available if loan included in income

Cost base of Lender FA shares to Canadian shareholder

Not applicable if loan is made to a non-resident
 Clarification that “upstream” and “downstream” surplus
balances included in respect of Lender FA’s chain of
ownership
 No restrictions in deductions if actual dividends paid by
Lender FA, other than rules to ensure no double-counting of
surplus, cost base
 Back-to-back loans collapsed to prevent double-counting of
income inclusions
36
Shawn Brade, CA
Upstream Loans – PreAcquisition Surplus
Example 1
 ‘Direct dividend hypothesis’ – if $200
dividend paid by FA to Canco
Forco
•
•
Canco
ACB $100
Loan $200
FA
$140 – pre-acq surplus
 Deduction for pre-acq surplus
dividend restricted to ACB – (clause
90(9)(a)(i)(D))
 Result
•
•
ES $60
37
$60 - exempt surplus
$200 income inclusion
$160 deduction for FA’s exempt
surplus ($60) and ACB ($100)
Shawn Brade, CA
Upstream Loans – PreAcquisition Surplus
Example 2
 Forco is a specified debtor
 ‘Direct dividend hypothesis’ – if $200
dividend paid by FA to Canco
Forco
•
Canco
ACB $100
FA
ES $60
Loan $200
•
$140 – pre-acquisition surplus
 Forco is non-resident person with
which Canco does not deal at arm’s
length. No deduction for Canco’s ACB
 Result
•
•
38
$60 - exempt surplus
$200 income inclusion
$60 deduction for FA’s exempt
surplus
Shawn Brade, CA
Upstream Loans –
Downstream Surplus
Example
Canco
FA1
Loan $300
•
FA3’s exempt surplus ‘elevated’ to
FA2
•
$200 deduction for FA2 and FA3’s
exempt surplus
FA2
ES $100
ES $100
 Previous – if $300 ‘upstream loan’
by FA2 to Canco, deduction for
$100 exempt surplus
 Amendment
FA 3
 FA1 is not a ‘downstream affiliate’
ES $100
39
Shawn Brade, CA
Upstream Loans –
Transitional Rules
 If loan outstanding on August 19, 2011, grandfathering rules
apply

If repaid prior to August 19, 2014, rules not applicable

If still outstanding on August 19, 2014, can treat as a new loan
made on that date, have 2 years to repay
 Post August 19, 2011 loans subject to 2-year repayment
period
40
Shawn Brade, CA
Foreign Tax Credit
Generators
 Set of new rules that will deny a deduction for foreign tax in
respect of FAPI included in taxpayer’s income
 Aimed at perceived abuses in amounts of foreign tax being
claimed as deductions or credits in Canada
 Apply if there is a hybrid instrument in a foreign affiliate
group

Shares for Canadian purposes treated as debt in other jurisdiction

Partnership interests subject to different income allocations
under Canadian and foreign rules
 Rules have been narrowed in scope from previous version
 Rules are generally applicable to taxation years ending after
March 4, 2010
41
Shawn Brade, CA
Foreign Tax Credit
Generators
 If responses to questions are all “yes”, rules will apply
42

Has a taxpayer (Canco) included amounts as FAPI in its income in
respect of a particular foreign affiliate (FAPI FA)?

Is there a hybrid instrument in place in Canco’s foreign affiliate
group?

Is owner of hybrid instrument either Canco or one of its foreign
affiliates?

Is issuer of hybrid instrument a foreign affiliate in same
ownership chain as FAPI FA?

Is owner considered to own less shares in issuer under foreign
tax law than under Act?
Shawn Brade, CA
Foreign Tax Credit
Generators
 Has Canco included amounts as FAPI in its income
in respect of a particular foreign affiliate (FAPI
FA)? = YES
Canco
Foreign
Holdco
Canada =>
Preferred shares
 Is there a hybrid instrument in place in Canco’s
foreign affiliate group? = YES
Foreign
jurisdiction =>
Debt
 Is owner of hybrid instrument either Canco or one
of its foreign affiliates? = YES, Canco
Foreign
Subco
 Is issuer of hybrid instrument a foreign affiliate in
the same ownership chain as FAPI FA? = YES,
Foreign Subco
 Is Canco considered to own less shares in Foreign
Subco under foreign tax law than under Act? =
YES, under foreign law Canco does not own any
preferred shares in Foreign Subco
FAPI
FA
 Rules therefore apply to deny Canco a foreign tax
deduction for any foreign tax paid by FAPI FA
43
Shawn Brade, CA
Foreign Tax Credit
Generators
Canco
Canada =>
Preferred shares
Luxembourg =>
Debt
Foreign
Holdco
Foreign
Opco
Issuer FA
(Lux)
 Has Canco included amounts as FAPI in
its income in respect of a particular
foreign affiliate (FAPI FA)? = YES
 Is there a hybrid instrument in place in
Canco’s foreign affiliate group? = YES
 Is owner of hybrid instrument either
Canco or one of its foreign affiliates? =
YES, Canco
 Is issuer of hybrid instrument a foreign
affiliate in the same ownership chain as
FAPI FA? = NO, Issuer FA is not in same
chain as FAPI FA
 Rules therefore do not apply to deny
Canco a foreign tax deduction for any
foreign tax paid by FAPI FA
FAPI
FA
44
Shawn Brade, CA
Foreign Tax Credit
Generators – Funding Rules
 Additional rules will apply if FAPI FA has received “funding”
from another FA of Canco, or a FA of a related Canadian
company


Funding includes loans, advances, asset purchases, dividends,
share redemptions
•
If loan has arm’s length terms and conditions, excluded as a source of
funding
•
Share acquisitions also excluded as a source of funding
If such funding exits, FAPI FA can be in a different chain of
ownership than hybrid instrument
 Funding rules apply to taxation years ending after October
24, 2012
45
Shawn Brade, CA
Foreign Tax Credit
Generators
Canco
Canada =>
Preferred shares
Luxembourg =>
Debt
Foreign
Holdco
Issuer FA
(Lux)
Foreign
Opco
Non-arm’s
length loan
FAPI
FA
46
 Without funding measures, rules are
not applicable as FAPI FA is not in same
ownership chain as Issuer FA
 Issuer FA has indirectly funded FAPI FA
 As a result, FAPI FA can be in different
ownership chain from Issuer FA
 Rules therefore apply to deny Canco a
foreign tax deduction for any foreign
tax paid by FAPI FA
Non-arm’s
length loan
Shawn Brade, CA

Foreign Affiliate Debt Dumping Rules
47
Shawn Brade, CA
Foreign Affiliate Dumping
Rules
 Rules introduced due to government’s concern with two
planning techniques that result in erosion of Canada’s tax
base


Leveraging Canada to create an interest deduction where funds
used to acquire FA shares – distributions from FA potentially taxfree
Paid-up capital creation in Canada, allowing for increased thin
capitalization room and ability to return capital to non-resident
with no withholding tax
 Draft legislation originally released August 15, 2012 with a
one-month consultation period
 Final rules included in Bill C-45 – October 18, 2012

Considered substantively enacted for Canadian GAAP and IFRS
purposes – has received First Reading
 Significant differences in two versions of rules
48
Shawn Brade, CA
Rules
 General application of rules unchanged


Canadian resident corporation (CRIC) is controlled by a nonresident corporation
CRIC makes an “investment” in a foreign affiliate (FA)
 Investment includes



Acquisition of shares of FA or contribution of capital to FA
Loans from CRIC to FA, or acquisitions of loans owing by FA by
CRIC from another person
•
Excludes certain loans or acquisitions made in ordinary course of
CRIC’s business
•
Excludes “pertinent loans or indebtedness”
Extension of maturity date of a loan, or date of redemption,
cancellation, acquisition of FA shares
49
Shawn Brade, CA
Rules
Base Case
Forco
International Tax 101
New Rules
Forco
Forco
Foreign
Canada
FMV = $1,000
PUC = $100
50
Acqco
PSH
PSH
Target
Target
FA
FA
FMV = $1,000
PUC = $1,000
CRIC =>
Acqco
PSH
FMV = $1,000
PUC = $100
Target
FA
=> >75% of
value
Shawn Brade, CA
Rules
 Results of application of rules

Deemed dividend equal to value of property (other than shares of
CRIC) transferred by CRIC related to investment
•

Dividend deemed paid by CRIC to non-resident parent – could result
in 15% or 25% withholding tax if shares of CRIC not owned directly by
parent
Increase in paid-up capital (PUC) of shares of CRIC issued in
respect of investment ignored
•
Will impact thin capitalization debt-to-equity limits
 Rules apply to transactions occurring after March 28, 2012

If written agreement in place between arm’s length parties prior
to March 29, 2012, transactions that occur before 2013 will not
be caught
51
Shawn Brade, CA
Rules
 Application of rules results in:
NR
Parent
Loan =
$1,500
CRIC =>
• PUC suppression = $700
Capital contribution
for shares = $700
Canco
Investment =
$2,500
FA
52
• Deemed dividend = $1,500 +
$300
 PUC suppression could result in
thin cap limits being exceeded –
interest deduction in Canco
deemed to be a dividend paid to
NR Parent
 If additional PUC balance remains
in Canco shares after PUC
suppression, deemed dividend
can be reduced
Shawn Brade, CA
Rules – Exceptions
 Business purpose test

Business activities of FA must be more closely connected to
business activities of CRIC than to business activities of nonresident

Stringent conditions to be met if test to apply
 Election to treat loan to a FA as a “pertinent loan or
indebtedness” eliminates deemed dividend

Results in imputed income inclusion equal to lowest prescribed rate
(currently 1%) + 4% if non-interest bearing
 Certain reorganizations exempted

Canadian reorganizations that could otherwise result in an
acquisition of FA shares
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Shawn Brade, CA

54
Thin Cap
Shawn Brade, CA
Thin Cap
Base Case
Partnership Loophole
0% WHT on Interest
Loophole
USco
USco
USco
Debt
Equity
Debt
200
Equity
100
Interest Rate 10%
WHT
0%
$300
0
Canco
Debt
Dividend
Interest
WHT
0%
Dividend
WHT
5%
99%
Canco
PSH
Canco
Partnership
Interest Expense $20
55
Interest Expense $30
No deduction for
dividend or for interest
in excess of 2:1
Shawn Brade, CA
Thin Capitalization Changes
 Maximum debt-to-equity ratio reduced from 2:1 to 1.5:1 for
determining the deductibility of certain interest on debt owed
to certain non-residents (e.g., related entities)
 Will apply to corporate taxation years beginning after 2012
 Rules extended to include partnership debt in the debt-toequity ratio

Will apply to corporate taxation years beginning after March 28,
2012
 Disallowed interest now treated as a dividend to the nonresident creditor that may be subject to withholding tax (with
potentially limited relief under a tax treaty)

56
Will apply to corporate taxation years ending after March 2012
Shawn Brade, CA

International Taxation - Canadian Tax Foundation

Transcription

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