Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(22)
Pure flow-through structure for designation of foreign business income (p 15)

An alternative to this structure [Canadian LP atop US LP atop US...

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Summary Under
Tax Topics - Income Tax Act - Section 113 - Subsection 113(1) - Paragraph 113(1)(c)
113(1)(c) deduction where LLC dividends paid after Cdn corporate member pays tax on LLC FAPI (p. 26)

If the LLC is a foreign affiliate earning...

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Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1)
Pooling of high and low state tax rates (p. 4)

Because the foreign tax credit is computed on a country-by-country pooling basis, where a...

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Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(2)
Reduction of Canadian taxes otherwise payable by losses (p.22:5)

Determining worldwide income involves many nuances that affect CTOP and therefore...

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Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax
Determination of partner's share of partnership tax (p.9)

[T]he suggestion [1.39 of S 5-F2-C1] that a taxpayer's share of taxes paid by a...

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Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11)
Non-deductibility on general principles (p.6)

Subsections 20(11) and 20(12) specifically override the limitation in paragraph 18(l)(a) which would...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 24
Re-sourcing of capital gains and derivative gains (p.7)

A common scenario in which a treaty re-sourcing rule may apply is where a Canadian...

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