Ilia Korkh, Eivan Sulaiman, "Outbound Partnerships: FAPI in Unexpected Places", Canadian Tax Highlights, Vol. 27, No. 12, December 2019, p. 10

Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(1)

Interposition of a partnership between a small stakeholder and a non-resident corp may generate FAPI (p. 10)

FAPI of a non-resident corporation...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B)

Interposition of partnership may engage s. 95(2)(a)(ii)(B) (p. 10)

[F]our arm’s-length Canadian corporations (Cancos) each own 25 percent of...

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