ULCs: From disregarded to denied
By
Katherine Chan
15d agoen
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millerthomson.comULCs: From disregarded to deniedmillerthomson.comCanada’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 on Miller Thomson .
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