Marc André Gaudreau Duval, Michael N. Kandev, "Foreign Affiliate Issues in Troubled Times", International Tax (Wolters Kluwer CCH), No. 112, June 2020, p. 1

Summary Under

S. 95(2)(g.1) applies on the basis of whether interest would be deductible from FAPI (pp. 2-3)

2002-0165195 … (the "2002 Technical") …...

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Summary Under

Questionable CRA position that forgiveness does not increase surplus (p. 4)

2002-0165195 … provides that the "exempt earnings" or "taxable...

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Summary Under

COVID-19 related deferral of foreign taxes may eliminate current FAT deduction (p. 5)

Assuming that an amount is not recognized as FAT until it is...

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Summary Under

Potential application of s. 248(27) to debt put to two uses (p. 3)

[R]espect[ing] debt partly used for the purposes of earning FAPI and partly...

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