Edward A. Heakes, "Another Wave of Foreign Affiliate Proposals", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1275

De minimis partnership interests are included in test (p. 1276

[I]f a taxpayer holds 5% of the shares of a listed company and is a partner in a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Avoidance of s. 85.1(4) eliminated (p. 1276)

It is currently arguably possible to avoid this limitation [in s. 85.1(4) by utilizing a triangular...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Narrowness of connected definition (p. 1275)

[A]ssume that A is a non-resident that owns 100% of the shares of two first tier Canadian holding...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.