The year 2012 brought significant Canadian tax developments in several areas.
The 2012 federal budget strengthened Canada's thin capitalisation rules by:
  • reducing the debt-to-equity limit from 2:1 to 1.5:1 (effective January 1 2013);
  • including debt incurred by a partnership of which a Canadian corporation is a member; and
  • treating disallowed interest as a dividend for Canadian withholding tax purposes.
Reprinted from Int’l Law Office, January 25, 2013

type Reviewing the Significant Tax Developments of 2012 (en anglais)