CRA is no longer requesting country-by-country breakdowns of income derived from mutual funds in its FTC audits
In the autumn of 2017, CRA requested numerous taxpayers to provide information respecting their foreign tax credit claims including as to the allocation of their income from Canadian mutual funds as between the U.S., Europe and Asia. This information was not available on the T3s issued by such mutual funds. In response to a query on this, CRA stated:
[W]here a mutual fund is invested in a significant number of countries and the burden of allocating the respective information may be burdensome to the taxpayer, the CRA will revise its administrative position and request taxpayers to provide an amended tax slip that correctly reflects the federal foreign tax credit amounts claimed. In general, the CRA will no longer systematically require a breakdown of foreign income by country, type of income and foreign taxes paid by country in such situations.
We have now published full-test translations of all the CRA and Finance responses to the questions posed at the two 2018 APFF Roundtables (together with summaries of the questions posed.) We have not summarized various questions posed at the 2018 APFF Financial Strategies and Instruments Roundtable to which the Finance representative did not provide written responses.
Neal Armstrong. Summary of 2018 APFF Financial Strategies and Instruments Roundtable, Q.12 under s. 126(1).