CRA confirms that a Canadian individual can claim a s. 20(11) deduction for US taxes (in excess of 15%) payable on distributed income of a non-CFA LLC

Where US tax is paid by a Canadian individual on the distributed income of an LLC (which is not a controlled foreign affiliate and therefore does not give rise to FAPI), CRA considers that the individual will be eligible for the deduction under s. 20(11) of the excess of the US tax paid over 15% of the dividends received even though such US tax is payable independently of whether or not it is distributed and, therefore, is paid independently of whether there is any corresponding income to the individual for Canadian purposes.

Neal Armstrong.  Summary of 2013 STEP Round Table, Q. 13, 2013-0480371C6 under s. 20(11).