Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Summary Under
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Ultimate Parent

Family trusts as ultimate parents (p. 3)

  • Although there are many instances in which a family trust could be treated as the ultimate parent of a...

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Summary Under
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Relevant Period

Application of group ratio where entry or exit from group (p. 3)

  • Given that the group ratio is calculated for a consolidated group for a...

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Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Cumulative Unused Excess Capacity

Recognition of CUEC when becoming subject to EIFEL (pp. 3-4)

  • Schedule 130 should accommodate taxpayers that become subject to the EIFEL rules...

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Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)

Iterative calculation of ATI where non-capital losses are used (p. 5)

The calculation and application of non-capital losses where the EIFEL...

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