International and EC Tax Aspects of Groups of Companies (Canada)

This short, largely descriptive piece reviews some of the history and reasons as to why the consolidation of corporate groups has not been adopted in the Canadian income tax legislation. Canada is unique becuase it is one of a very limited number of high-income countries with no formal consolidate regime. After a brief review of the history of consolidated reporting in Canada, the piece describes some of the instances where a mutuality of interest between corporations is recognized, the objectives of recognizing a group of corporations in these instances, and the measures of relatedness used to group corporations. Measures that allow corporations to share tax attributes, and in particular corporate losses, in the domestic context are examined first and then a few measures that allow for the sharing of tax attributes cross-border are reviewed. Before proceeding with this review, in order to provide some context, a few other broad outlines of the Canadian corporate tax system are highlighted.