CRA appears to have discussed an amendment to the upstream loan rules with Finance

As noted in a previous post, CRA considers that the amount of an upstream loan owing by Canco to a CFA will be included in Canco’s income when the CFA is wound-up. In CRA’s written responses to the 2014 CTF Roundtable questions which were released on
Thursday evening, CRA stated (more crisply than in its oral presentation):

We anticipate that this issue will likely be resolved eventually through legislative amendment.

Neal Armstrong. 24 November 2015 CTF Annual Roundtable, Q. 8.