CRA provides additional guidance on the foreign tax credit rules

The draft CRA folio on foreign tax credits incorporates most of the material in IT-270R3, but also adds some discussion.  For example, it provides guidance on how the taxpayer is permitted to allocate allowable capital losses amongst different countries where the taxpayer’s global capital losses exceed its global capital gains for a year, and also notes, with respect to the "economic profit" rule (in s. 126(4.1)), that the rule is not applied independently to a related transaction involving another property acquisition.

Neal Armstrong.  Summaries of S5-F2-C1:  "Foreign Tax Credit" 27 March 2013 under ss. 126(1), 126(2), 126(4.1), 126(7) – business-income tax, 126(7) – non-business-income tax, 4(3), 110.5, 115(1)(a)(i) and 115(1)(a)(ii), and under General Concepts - Agency.