New FAPI pick-up rule (similar to Code s. 951(a) rule) is on hold for reworking

Proposed ss. 91(1.1) and (1.2) would now potentially require a FAPI pick-up where a CFA interest has been disposed of before year end, so that the FAPI pick-up generally will not now be avoided through not holding the CFA at that year end. The comparable U.S. rule is that pro rata portions of Subpart F income must be recognized unless the disposition occurs in the first 30 days of the CFC's taxable year and the sale is to a non-U.S. person.

This proposed rule was not included in the recently enacted Bill C-43 because it is being reworked by Finance.

Neal Armstrong. Summary of Nathan Boidman, "Canada Augments International Tax Rules", Tax Management International Journal, Vo. 43, No. 12, December 12, 2014, p. 759 under s. 91(1.1).