ULCs: From disregarded to denied
Canada’s Phase 2 hybrid mismatch rules — Here is what to do before July 1, 2026. Starting July 1, 2026, the Phase 2 amendments to Canada’s hybrid mismatch arrangement rules in s. 18.4 of the Income Tax Act (the “HMA Rules”) will deny deductions on a far broader set of payments than Phase 1 reached. […] The post ULCs: From disregarded to denied appeared first