Hybrid Mismatch Rules: Tax Insights from the Second Round of Finance Proposals

The Department of Finance (Canada) (“Finance”) recently released its second round of proposals related to hybrid mismatch arrangements (the “Round 2 Proposals”). These new rules, which build upon a first round of proposals originally introduced in 2022 (the “Round 1 Proposals”), are complex and could have broad implications.... By: Stikeman Elliott LLP