28 STRUCTURING MINING INVESTMENTS
28 Corporate Reorganizations
29 Tax-Deferred Transfers
29 Amalgamations
29 Wind-Ups of Subsidiaries
30 Acquisition of Control
31 Partnerships and Joint Ventures
33 Income Tax Consequences
34 Advantages of Partnerships
35 Farm-Ins/Farm-Outs
36 Foreign Operations
36 Operation Through a Branch
36 Operation Through a Foreign Corporation
38 Foreign Affiliates
38 The Foreign Affiliate Regime
38 The Surplus Rules
40 The FAPI Rules
44 Non-Resident Investors
44 Acquiring Assets Versus Acquiring Shares
45 Operating in Canada Through a Branch
46 Operating in Canada Through a Subsidiary
© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
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A Guide to Canadian Mining Taxation