Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231

Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4.1)

The FAT [foreign accrual tax] or UFT [underlying foreign tax] denied under the FTCG [foreign tax credit generator] Rules is not limited to the...

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Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4.7)

After referring to the expansion of the income test in s. 91(4.1)(a) by virtue of the deductible dividend test in s. 91(4.7), they stated:

… On...

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