Edward A. Heakes, "Another Wave of Foreign Affiliate Proposals", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1275

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property
De minimis partnership interests are included in test (p. 1276

[I]f a taxpayer holds 5% of the shares of a listed company and is a partner in a...

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Summary Under
Tax Topics - Income Tax Act - Section 87 - Subsection 87(8.3)
Avoidance of s. 85.1(4) eliminated (p. 1276)

It is currently arguably possible to avoid this limitation [in s. 85.1(4) by utilizing a triangular...

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Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(1.2)
Narrowness of connected definition (p. 1275)

[A]ssume that A is a non-resident that owns 100% of the shares of two first tier Canadian holding...

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