Subsection 5900(3)
Administrative Policy
16 May 2018 IFA Roundtable Q. 3, 2018-0749171C6 - Interaction s.91(5) s.93.1(2)(d)(i)
Canco (and its Canadian sub) hold LP, which received a $3,000 dividend from a wholly-owned foreign affiliate (FA). Although the dividend came out...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 93.1 - Subsection 93.1(2) - Paragraph 93.1(2)(d) - Subparagraph 93.1(2)(d)(i) | s. 93.1(2)(d)(i) limit does not reflect acquisition-debt interest deduction of LP | 418 |
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(5) | appplication of s. 91(5) to LP shareholder of FA | 88 |
27 June 2008 External T.I. 2007-0247551E5 - FAPI and Part XIII Tax
A partnership (FP) between two CFAs of Canco received dividends from a non-resident subsidiary of FP (NRco) and on-paid those dividends to its two...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | DRUPA partnership | 38 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Property Income - A - Paragraph (b) | FA dividends received by NR partnership between 2 CFAs (FP) not excluded from FAPI, but deduction under s. 91(5)/ Reg. 5900(3) to FP | 298 |
| Tax Topics - Income Tax Act - Section 92 - Subsection 92(1) - Paragraph 92(1)(a) | double ACB recognition of FAPI at partnership level and at level of Canco shareholder of CFA partners | 230 |
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(5) | s. 91(5) deduction eliminated net FAPI inclusion to CFA members of foreign partnership receiving foreign dividends from partnership subsidiary | 107 |