Joint Committee, "Submission on Hybrid Mismatch Arrangements - Technical Comments and Recommendations", 5 June 2026 Joint Committee Submission

Summary Under
Tax Topics - Income Tax Act - Section 18.4 - Subsection 18.4(1) - Ordinary Income

Finance approach to determining “ordinary income” (p. 1-2,6-7)

  • The Joint Committee learned in discussions that Finance considers an amount...

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Summary Under
Tax Topics - Income Tax Act - Section 18.4 - Subsection 18.4(1) - Foreign Hybrid Payer Mismatch Rule

Examples re interaction of hybrid mismatch and US DCL rules (pp. 7-12)

The Joint Committee was requested to make further submissions on the...

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Summary Under
Tax Topics - Income Tax Act - Section 18.4 - Subsection 18.4(7.1)

Computation of deduction component of double deduction mismatch (pp. 13-14)

  • Based on the language in draft ss. 18.4(7.1) and (7.2), where any...

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Summary Under
Tax Topics - Income Tax Act - Section 214 - Subsection 214(18)

Policy reason for withholding under s. 214(18) is to avoid abuse of the thin cap rules (p.15)

  • The Joint Committee learned from discussions with...

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