Mark Dumalski, "The Unexpected Implications of Canada's Latest Anti-Hybrid Proposals", International Tax Highlights, Vol. 5, No. 2, May 2026, p. 4

Summary Under
Tax Topics - Income Tax Act - Section 18.4 - Subsection 18.4(15.6)

ULC example of dual-inclusion income not being recognized as ordinary income of the investor country (p. 5)

  • The hybrid payer rules can lead to...

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Summary Under
Tax Topics - Income Tax Act - Section 18.4 - Subsection 18.4(15.94)

No need for causal link (p. 6)

Regarding the imported mismatch arrangement rules, the Canadian rules align with the Action 2 recommendations in...

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