Paul Dhesi, Korinna Fehrmann, "Integration Across Borders", Canadian Tax Journal, (2015) 63:4, 1049-72

Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4)

Inclusion of FAPI in aggregate investment income ("AII") (p.1052)

[F]API, as income earned from a share, should be included in a CCPC's AII in the...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(b)

Likely disadvantage of generating services income as FAPI (pp. 1055-6)

[C]onsider a Canadian company ("Canco") that sells its product directly to...

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Summary Under
Tax Topics - Income Tax Act - Section 93 - Subsection 93(1)

Inefficiency of realization of capital gains by CFA of CCPC (p. 1062, 1064)

[T]he realization of capital gains at the CFA level...is rarely good...

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Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(d)

Safe income of foreign affiliate (pp. 1069-1071)

Conceptually, the modified "tax-free surplus balance" definition in paragraph 55(5)(d) is the...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2.1)

Advantage of book depreciation election (p.1071)

[A]n election is available under regulation 5907(2.1) to use book depreciation rather than tax...

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