The Wonderful World of Compliance: Complex Transactions, Recent Changes and Other Nuances

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1 The Wonderful World of Compliance: Complex Transactions, Recent Changes and Other Nuances April 19, 2016 Dana Birch and Michel Bourque kpmg.ca/tax

2 Agenda Topic 1. Welcome and Introductions 2. Selected Canadian Compliance Matters 3. Recent US Developments Federal Budget Update 5. Questions and Wrap-up 2

3 Selected Canadian Compliance Matters 3

4 15(2.11) Pertinent Loan or Indebtedness Elections Election avoids the application of ss. 15(2) and 17(1) on loans to non-residents Deemed interest income to Canco Election due with the tax return for the year the loan is made Repayment within 2 years PLOI is not applicable Protective PLOI election is possible If repayment occurs, amend tax returns and request a refund Late filing Late filed election is possible within 3 years of filing due date Penalty is minimal ($100 / month) Late file election if there s a chance of repayment? Loan Canco NR Co Loan NR Sub Co 4

5 Upstream Loans Certain loans to specified debtors from foreign affiliates included in income Included in income of the taxpayer, not the creditor NR Parent Timing of inclusion = taxation year that includes the loan Surplus Deduction for surplus available at the time of the loan 90 day rule? No pre-acquisition surplus for some loans Upstream Loan Canco Upstream Loan Surplus deduction is included in income next year, fresh surplus deduction taken FA1 Repayment Deduction in year of repayment Ensure actual repayment occurs 5

6 T1134 Information Return Relating to Foreign Affiliates - Due 15 months after year-end - Lowest tier affiliate reports, unless another taxpayer has a direct interest New exemption threshold: Total cost amount of all foreign affiliate interests is less than $100,000 and the foreign affiliate is dormant/inactive Dormant/inactive = gross receipts less than $25,000 and FMV of assets less than $1m Receipts includes all receipts, not just income (e.g. loans) Common mistakes: Organizational structure reporting (administrative relief available) Services or passive income not reported Passive income reported but appropriate re-characterization/exclusion not selected Foreign affiliate not reported if there was no foreign tax-year end in the taxpayer s year-end Short Canadian tax years (administrative relief available) 6

7 T1135 Foreign Income Verification Statement Reports specified foreign property held by Canadian resident taxpayers Often missed for corporations and partnerships still applies Filing threshold cost amount of all specified foreign property exceeds $100,000 Important because omissions open up tax years not just a potential penalty anymore Foreign bank accounts, loans, etc not used in Canco s active business Shares of non-resident entities that are not foreign affiliates (e.g. less than 1%/10% interests) 7

8 T1135 Foreign Income Verification Statement - Example Canco must file T1135 in respect of Loan 1 and its interest in FA1 FA1 is not a foreign affiliate of Canco 1 for this purpose Loan 2 is exempt due to the foreign affiliate debtor exemption Canco 1 100% Loan 1 0.1% Canco 2 99% Loan 2 FA1 8

9 T106 Information Return of Non-Arm s Length Transactions with Non- Residents Filing Requirements: Total cross-border transactions with all foreign related parties more than $1m If transactions with a specific non-resident total less than $25,000, Part III of T106 slip not required Late-filing penalty: greater of $100 and $25/day up to maximum penalty of $2,500 (per T106 slip) Common mistakes: Box 6 = no or blank Less than $25,000 transactions and not filing T106 slip Reimbursements as services Missing or misclassifying transactions Netting transactions Listing FX as a transaction Incorrect method 9

10 Regulation 105 Withholding on fees, commissions and other amounts paid by any person to a non-resident in respect of services rendered in Canada Issues: Wide application (applies between two non-residents) Seeing a lot of CRA activity in this area, and see significant non-compliance Penalty is 10% of tax that should have been withheld, failure to file on T4A-NR, plus failure to file for non-resident tax return, if applicable Treaty based returns for non-resident justifying treaty position under audit may be difficult Permanent establishment returns for non-resident transfer pricing Regulation 102 withholding and returns for employees performing the service Solutions: Lots of detail on invoices Structure services from related non-residents as a secondment? Some amounts potentially exempt (see Weyerhaeuser)? Waiver? 10

11 Regulation 102 Withholding on employment exercised in Canada New treaty-based waivers 2015 draft legislation provides an exception from withholding tax requirements for qualified employers and qualified employees The employer must be certified - Form RC 473 Application for Non-Resident Employer Certification The employer must monitor and have documentation to ensure employees are qualified employees Employee must work in Canada < 45 days in calendar year or must be present in Canada for < 90 days in any 12-month period that includes the time of payment Employee musts be resident in a country with which Canada has a tax treaty Apply 30 days before qualifying employee starts work in Canada Form R102-R Regulation 102 Waiver Application Project basis, application is limited Must be submitted 30 days before start of employment in Canada or the initial payment for employment 11

12 GST Closely Related Corporations New filing requirement for election for closely related corporations came into effect on January 1, 2016 (form RC4616) CRA Audit Activity Aggressive in denying ITCs where the entity name on the invoice does not match the entity in which the ITC was claimed CRA assessing gross negligence penalties where repeat errors have occurred, even see this on refund claims 12

13 Unpaid Amounts 78(1) Applies to unpaid amounts owing to non-arm s length persons for more than 2 taxation years If applicable, unpaid amount is included in the taxpayer s income in year 3 Very common scenario of application is in respect of interest Administrative policy on 78(1) if debtor and creditor use accrual method Consider using strategy in Hill - Exchange cheques capable of being honored - Daylight loan Turn interest in to principal amount owing Good opportunity to review debt - Interest rate still reasonable - Satisfies realness of loan Election possible 13

14 Recent U.S Developments 14

15 Section 385 Section 385(a) provides Treasury with the authority to issue regulations as may be necessary or appropriate to: Determine whether an instrument is debt or equity for U.S. tax purposes, and Bifurcate an instrument as part debt and part equity Section 385(b) includes a non-exhaustive list of factors that may be taken into account in determining whether an instrument is debt or equity for U.S. tax purposes: Whether the instrument includes a written unconditional promise to pay a sum certain and fixed interest rate Whether the instrument is subordinated to, or given preference over, other indebtedness The issuer s debt-to-equity ratio Whether the instrument is convertible into the issuer s stock The relationship between holding stock of the issuer and instrument Section 385(c) states that the issuer s characterization of an instrument at the time of issuance is binding on the holder, but not the IRS, unless the holder discloses the inconsistent treatment, and provides Treasury with authority to require information necessary to carryout the provisions of the subsection 15

16 Proposed Regulations: Overview Proposed Regulations include rules Providing the IRS with the ability to bifurcate an instrument as part debt and part stock Setting forth documentation and maintenance requirements that must be satisfied for a related-party instrument to be characterized as debt for U.S. tax purposes Subject to certain exceptions, re-characterizing related-party debt instruments as stock for all U.S. tax purposes when issued: (i) as a distribution, (ii) in exchange for related-party stock (e.g., section 304 sale), (iii) as consideration in an internal asset reorganization (e.g., a boot D reorganization), or (iv) to fund a distribution, acquisition of related-party stock, or boot in an internal asset reorganization Apply without regard to whether (i) the parties are domestic or foreign, or (ii) the corporate group effected an inversion Members of a U.S. consolidated group are treated as a single entity, so the regulations do not apply to debt between consolidated group members 16

17 Effective Dates The documentation requirements and bifurcation provisions are generally effective for Applicable Instruments issued or deemed issued after the regulations are published as final The re-characterization provisions are generally effective for Expanded Group ( EG ) Debt Instruments issued on or after April 4, 2016 The re-characterization provisions, however, include limited transition rules that provide that a Debt Instrument issued before the regulations are finalized and that would be recharacterized as stock under the regulations is treated as debt only for the 90 days after the regulations are finalized; on the 91st day any outstanding instruments are deemed exchanged for stock 17

18 Documentation Requirements: Not Applicable to Small Taxpayers The documentation requirements only apply to an Expanded Group Instrument ( EGI ) if: The stock of any EG member is traded on, or subject to the rules of, an established financial market within the meaning of Treas. Reg (d)-1(b), On the date the Applicable Instrument first becomes an EGI, the EG s total assets exceed $100 million on any Applicable Financial Statement (defined by Prop. Reg (a)(4)(iv)), or On the date the Applicable Instrument first becomes an EGI, the EG s total annual revenue exceeds $50 million on any Applicable Financial Statement 18

19 Documentation Requirements Written documentation establishing that the Issuer has entered into an unconditional and legally binding obligation to pay a sum certain on demand at one or more fixed dates ( Documentation Requirement 1 ) Written documentation establishing that the holder has the typical creditor rights (e.g., trigger or acceleration right upon non-payment and right to sue to enforce payment), which must include a superior liquidation right to shareholders ( Documentation Requirement 2 ) Written documentation establishing that, as of the date of issuance and taking into account all the relevant circumstances, the Issuer s financial position supported a reasonable expectation that it intended to, and would be able to, meet its obligations pursuant to the terms of the instrument ( Documentation Requirement 3 ) Evidence of the holder s efforts to assert creditor s rights ( Documentation Requirement 4 ) - Written evidence payments of principal or interest e.g., a wire transfer or bank statement showing payments - In the event payment not in accordance with the EGI s terms or other default, there must be written documentation evidencing the holder s reasonable exercise of the diligence and judgment of a creditor 19

20 Timing of Documentation Each of the Documentation Requirements must satisfied within a specified time Documentation Requirements 1-3 are timely if documentation is prepared no later than 30 calendar days after the Relevant Date Documentation Requirement 4 is timely if documentation is prepared no later than 120 calendar days after the Relevant Date If an Applicable Instrument becomes an EGI after it is issued, no date before the instrument becomes an EGI is a Relevant Date Satisfying the Requirements does not establish that an EGI is debt, but failure to satisfy the requirements means an EGI is stock The type of stock (e.g., common or preferred) is based on the EGI s terms and conditions Reasonable Cause Exception If a taxpayer characterizing an EGI as debt establishes reasonable cause for failure to satisfy any of the Requirements, appropriate modifications may be made in determining whether the Requirements have been satisfied 20

21 Re-characterization General Rule Unless an exception applies, a Debt Instrument issued by a corporation to an EG member is treated as stock if it is issued: In a Distribution, In exchange for the stock of a member of the same EG ( EG Stock ) or In exchange for property in an asset reorganization if the instrument is received, pursuant to the plan of reorganization, by a transferor corporation shareholder that is an EG member with respect to its transferor corporation stock A Distribution is any distribution made by a corporation with respect to its stock 21

22 Federal Budget Update 22

23 2016 Federal Budget Proposals BEPS Broad statements regarding Treaty abuse Canada actively participating in development of multilateral instrument Exchange of tax rulings CRA to commence spontaneous exchange in 2016 Not included BEPS-related changes other than country-by-country reporting (CbyCR) proposals No announcements regarding other OECD Action Plans hybrid arrangements, interest deductibility 23

24 2016 Federal Budget Proposals CbyCR Draft legislation to implement requirement to submit CbyC Report to be released in coming months Applicable for taxation years beginning after 2015 Applicable to groups with consolidated annual revenue of > 750M Look to top entity in chain required to consolidate controlled subsidiaries 24

25 2016 Federal Budget Proposals Debt Parking Loan $100 USD 3 rd Party Inherent f/x gain at time of loan repayment At time loan made $100 USD = $100 CAD At time of repayment $100 USD = $90 CAD Rather than repayment, loan acquired by CanSub Canco No change in debtor no settlement of debt, no f/x realization event CanSub Loan $100 USD Proposed legislative change At time loan acquired by non-arm s length person it becomes a parked obligation Debtor deemed to realize f/x gain as if loan repaid at that time Applies to foreign currency debt that meets conditions on or after March 22/

26 2016 Federal Budget Proposals Back-to-Back Arrangements Non- Resident Canco Intermediary Debt Intermediary Obligation Current withholdings tax (w/h) tax rules for back-to-back loan arrangements Canco has obligation to Intermediary (any non-resident or arm s length Canadian) and pays interest thereon Intermediary has an obligation (Intermediary Debt) to a Non-Resident Obligation is either limited recourse debt, or there is an interconnection between both obligations W/T liability to Non-Resident would be greater than w/h tax liability to Intermediary Result interest deemed paid to Non- Resident and not to Intermediary 26

27 2016 Federal Budget Proposals Back-to-Back Arrangements Non- Resident Intermediary obligation Intermediary Budget proposes to extend rules to back-toback royalty arrangements, and other arrangements that are economically similar to interest/royalties Will apply to arrangements that are sufficiently connected to each other Applies to royalty payments after 2016 Canco Royalty obligation 27

28 Questions 2016 KPMG LLP, a Canadian 2016 KPMG limited LLP, liability a Canadian partnership limited and liability a member partnership firm of and the KPMG a member network firm of independent the KPMG network member of firms independent affiliated member with KPMG firms International affiliated with Cooperative KPMG International ( KPMG 28 Cooperative ( KPMG

29 Contacts Dana Birch International Tax Partner, Calgary, KPMG in Canada T: E: Michel Bourque KPMG Law Partner, Calgary, KPMG Law LLP T: E: 29

30 Detail Heading Detail Heading Detail Heading Detail Heading kpmg.ca/tax This presentation may contain a discussion or analysis of decided tax cases. Any discussion or description of the facts of the case or the positions argued by the parties is based solely on publicly available information. For greater certainty no confidential client or taxpayer information is disclosed. This information is current to April 5, The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. The KPMG name and logo are registered trademarks of KPMG International.

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