What people are saying - Write a review
We haven't found any reviews in the usual places.
Chapter Title 1 Summary of Provisions
Meaning of Foreign Affiliate
Result of Foreign Affiliate Status
24 other sections not shown
accrual property income acquired affiliate active business carried active business income adjusted cost base affiliate in respect affiliate's taxable surplus apply arm's length became a foreign beneficiary calculated Canadian corporation Canadian taxpayer capital cost allowance capital gain capital loss capital property capital stock class of shares controlled foreign affiliate corporation resident deal at arm's deficit and underlying direct equity percentage discretionary trust disposing affiliate dividend received earnings amount election under subsection exempt deficit exempt earnings fair market value FAPI foreign accrual property gain or loss included income or profits Income Tax merger non-resident corporation November 12 paragraph 95(2 participating percentage particular affiliate particular foreign affiliate portion pre-acquisition surplus preceding taxation predecessor corporation prescribed proceeds of disposition profits tax paid provides purposes Regulation 5905 resident in Canada rules shareholder subsection 93(1 surplus in respect taxable deficit taxable earnings taxable income tion trust underlying foreign tax withholding tax