On September 3, 2026, TEI submmited comments to the Canadian Department of Finance ("Finance") regarding proposed rules to combat cross-border hybrid mismatch arrangements. TEI recommended Finance follow the approach of the European Union which, after many years attempting to administer its hybrid rules, decdided to repeal them in their entirety. As an alternative, if Finance decides not to repeal the rules, TEI recommended the rules be narrowed to take into account other regimes that effectively combat hybrid mismatches, such as the U.S. dual consolidated loss rules. TEI's comments were prepared under the aegis of its Canadian Income Tax Committee, whose Chair is Sandy Shanks.
Read the Comments HERE
Committee