Summary UnderTax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses Separate flow-up of relevant affiliate IFE or relevant affiliate IFR (p. 4) The amounts that would be the interest and financing revenues (IFRs)...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A) IFE of CFA not restricted (p. 4) Per s. 95(2)(f.11)(ii)(A), the EIFEL rules should not restrict the IFE of the CFA for the purposes of...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D) No carryforward (pp. 4-5) Per s. 95(2)(f.11)(ii)(D), where a portion of a taxpayer’s IFE for a taxation year is denied under s. 18.2(2), the...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b) Earnings not subject to EIFEL adjustments (p. 6) “Earnings” under para. (b) of the Reg. 5907 definition (essentially, FAPI recharacterized as...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues Various imputed amounts not included (p.6) The IFR definition will not be amended to include amounts under ss. 16.1, 17 and 247(2), and draft...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h) Potential need to determine pre-EIFEL IFR and IFE (p. 7) Given the potential to carry forward losses from pre-EIFEL years, taxpayers may be...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) Transferee can have a different functional currency or be a REIT (p. 7) The EIFEL revisions have removed the requirement that cumulative unused...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a) Can be different reporting currencies (p. 9) Under an amendment to s. 18.21(2)(a) of the group ratio rules, the requirement that the tax...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio Grind removed (p. 9) The amended “group ratio” definition has removed the progressive grind (formerly in para. (b) of “group ratio”). Email this Content
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