Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8

Summary Under

General potential triggering of stub year for controlled foreign affiliate (CFA) if disposition triggering change to surplus entitlement...

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Summary Under

Stub period for CFA applies re NAL Cdn corps (p. 10)

[T]his deemed [s. 91(1.2)] year end applies… also in respect of each corporation or...

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Summary Under

Need not be two dispositions for s. 91(1.4) to apply, and excluded property condition may be meaningless (p. 11)

Subsection 91(1.4) is designed to...

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Summary Under

Potential relieving effect of s. 91(1.5) (p. 12)

Subsection 91(1.5) is designed to address the interaction of subsection 91(1.2) and the...

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