2012 amendment to s. 92(1)(a) means that statute-barring period for FAPI does not start running until it is distributed

The wording of the ACB addition for foreign accrual property income in s. 92(1)(a) was amended effective 2012 to replace "any amount required to be included…by reason of subsection 91(1)…in computing the taxpayer's income", by "any amount included…under subsection 91(1)."  The likely effect is that if CRA is statute-barred from assessing Canco for FAPI earned by FA in a year, it can still indirectly assess that FAPI by denying a s. 91(5) deduction to Canco when FA distributes that FAPI as a dividend (and similarly where "Canco" is an individual).

Neal Armstrong.  Summary of Allan Lanthier, "FAPI or Taxable Surplus Dividend," Canadian Tax Highlights, Vol. 23, No. 2, February 2015, p. 4 under s. 92(1)(a).