Cric

(redirected from CRICS)
Also found in: Acronyms.
Related to CRICS: CRISC, BRICS, Crocs
(krĭk)
n.1.The ring which turns inward and condenses the flame of a lamp.
Webster's Revised Unabridged Dictionary, published 1913 by G. & C. Merriam Co.
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References in periodicals archive ?
The draft legislation includes two measures that apply to investments in nonresident corporations (the subject corporation) by a corporation resident in Canada (CRIC) controlled by a non-resident parent corporation.
Three relieving provisions permit CRIC's to undertake certain business transactions without being ensnared by the rules.
Specifically, we see no abuse of the Canadian tax system where cash generated by a CRIC's business is invested downstream in the common shares of a controlled foreign affiliate and the CRIC is entitled to both the growth potential of the downstream investment and future cash repatriations on those common shares.
Relief should be afforded from draft section 212.3 for a CRIC that holds a controlling common share interest in a foreign affiliate or makes additional common share investments in a controlled foreign affiliate.
Subsection 212.3(12) provides a relieving exception where an investment is made by a CRIC in a "strategic business expansion." The Budget proposal sets forth a list of factors to consider in determining whether an investment in a foreign affiliate was made primarily for a bona fide business purpose other than to obtain a tax benefit.
The Institute explained that, taken together, these provisions will so restrict a CRIC's ability to manage and invest its cash flows that the effective corporate income tax rate on nonresident corporate groups will increase from 25 to approximately 30 percent (or more) depending on the withholding rate on dividends.
In other words, CRICs will not be able to invest in or lend to other group companies without triggering one of the taxing provisions.
The budget proposes to curtail "foreign affiliate dumping" transactions through two measures applicable to certain investments in non-resident corporations (the subject corporation) by a corporation resident in Canada (CRIC) controlled by nonresident parent corporation.
Regrettably, the interaction of the foreign affiliate dumping proposal, the upstream loan proposal in the Foreign Affiliate Amendment package released by the Department on August 27, 2011, and current subsection 15(2) of the Act will so restrict a CRIC's ability to manage and invest its cash flows that the effective corporate income tax rate on non-resident corporate groups will be viewed as increasing from 25 to approximaTEIy 30 percent or more depending on the withholding rate on dividends.
Canadian-based businesses." To distinguish whether an investment is made by a CRIC instead of being "made or retained" by the nonresident parent (or another non-arm's length nonresident) primarily for bona fide purposes other than to obtain a tax benefit, proposed paragraph 212.3(5) enumerates seven "factors that are to be given primary consideration" for determining whether the business purpose test is satisfied.