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. … [A] Canadian taxpayer that indirectly holds an interest in an LLC through a shareholder affiliate would be entitled to a deduction under 91(4) for tax paid by the shareholder affiliate in respect of FAPI earned by the LLC. ...

. … Double taxation for corporate LLC members until dividend (p. 18:27) [U]nlike individual members, corporate members are effectively subject to double taxation on FAPI inclusions until the income is repatriated. ...

. … Potential for taxpayers to direct where their tax refunds are paid (p. 9) This is a sensible, practical decision that points to the failure of section 116 to contemplate court-ordered sales of property. ...

On a subsequent sale by the trust of the shares to a third party, the QSBC definition would require that the shares have been owned by the trust, or a person related to the trust, for the prior 24-month period – and in this regard, s. 110.6(14)(c)(ii) provides that where a person who sold shares to a trust was related to all the beneficiaries, that person and the trust are deemed to have been related for the above purpose. ...

Thus for example, if a partnership (with corporate partners which are not professional corporations) is formed on December 29, 2021, it must close off its first fiscal year on December 31, 2021 (in which case it could incur penalties under s. 162(7.1) of up to $2,500 if it forgets to file a return for that three-day year) – or, alternatively, it most close off its year at some later date partway through 2022 (e.g., June 30, 2022) and apply to CRA pursuant to s. 249.1(7) for advance permission to change the second fiscal period end to December 31, 2022. ...

(b) thereof requires that the LLC be treated as fiscally transparent in Canada, which is not the case – so that the 25% withholding tax rate is not reduced. ...

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022-- summary under Paragraph 111(1)(a.1) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a.1) Effect of carrying forward cumulative unused excess capacity for 3 years is similar to a 3-year carryback (p. 6) IFE that is denied under new subsection 18.2(2) (and amounts included under new paragraph 12(1)(l.2) in respect of a member’s share of denied partnership IFE …) may be carried forward up to 20 years. ...

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)-- summary under Subsection 110(1.3) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1.3) Potential to free-up annual limit room through exchange of underwater options (pp. 15-16) If, for example, in 2022, an option agreement, that had been made in 2021 and provided for even vesting for $200,000 of shares evenly over 2022 to 2026 (so that the vesting room was fully utilized for those years), was exchanged under s. 7(1.4) for options whose vesting was all to occur in 2026, it would appear to remain the case that a new option agreement had been made, so that s. 110(1.3) likely would require the re-application of the annual vesting limit – so that with all the vesting occurring in 2026, only $200,000 of such vesting would be within the limit. ...

The concern expressed in the Explanatory Notes- that the current rules allowed the accrued gain from the acquisition of shares or debt of a Canadian-resident corporation to be deferred indefinitely while still allowing a Canadian-resident corporation to have use of the underlying property (eliminated altogether through a subsequent reorganization) – might have been addressed more narrowly by requiring that the capital property be foreign capital property. ...

., where two controlled foreign affiliates (“CFA1” and “CFA2”); of Canco wholly-own LP, which wholly owns “CFA3,” with CFA3 incurring interest expense that is otherwise deductible in computing its FAPI relative to LP – given, inter alia, that LP is not a “taxpayer" (as defined in draft s. 18.2(1)) for EIFEL purposes and draft s. 95(2)(f.11)(ii)(A) provides that s. 18.2(2) does not apply for purposes of computing FAPI of a foreign affiliate. ...