Section 91

Subsection 91(1) - Amounts to be included in respect of share of foreign affiliate

Articles

Jonah Bidner, "An Individual's Direct Ownership of a CFA", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p. 12

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Kevin Duxbury, "Canadian-Owned US LLCs More Costly After the Fifth Protocol", Tax for the Owner-Manager, Vol. 9, No. 4, October 2009, p. 8.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 4 0

Pierre Bourgeois, "Canadian Taxation of Offshore Income: A Primer", 1999 Conference Report, c. 2.

Subsection 91(1.1)

Articles

Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016

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Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8

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Melanie Huynh, Paul Barnicke, "September 2016 FA Proposals", Canadian Tax Highlights, Vol. 24, No. 10, October 2016, p. 8

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Nathan Boidman, "Canada Augments International Tax Rules", Tax Management International Journal, Vo. 43, No. 12, December 12, 2014, p. 759.

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Subsection 91(1.2)

Articles

Monique Sami, "Further Refinements to Stub Period FAPI", International Tax (Wolters Kluwer CCH), October 2017, No. 96, p. 4

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Paul Barnicke, Melanie Huynh, "Revised Stub-Period FAPI", Canadian Tax Highlights, Vol. 25, No. 10, October 2017, p. 3

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Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016

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Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8

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Paul L. Barnicke, Melanie Huynh, "Stub Period FAPI on Disposition", Canadian Tax Highlights, Vol. 21, No. 8, p. 6

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Edward A. Heakes, "Another Wave of Foreign Affiliate Proposals", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1275

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Subsection 91(1.4)

Articles

Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016

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Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8

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Subsection 91(1.5)

Articles

Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016

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Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8

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Subsection 91(4) - Amounts deductible in respect of foreign taxes

Administrative Policy

25 March 2004 Miscellaneous 2002-0134201I7 - Foreign accrual tax-timing of Deduction

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Articles

Paul Dhesi, Korinna Fehrmann, "Integration Across Borders", Canadian Tax Journal, (2015) 63:4, 1049-72

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Michael G. Bronstetter, Douglas R. Christie, "The Fickle Fingers of FAT: An Analysis of Foreign Accrual Tax", International Tax Planning, 2003 Canadian Tax Journal, No. 3, p. 1377.

Melanie Huynh, Eric Lockwood, "Foreign Accrual Property Income: A Practical Perspective", International Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 3, p. 752.

Subsection 91(4.1) - Denial of foreign accrual tax

Articles

Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4.7) 232

Angelo Nikolakakis, "Foreign Tax Credit Generators - Revised Proposals, Continuing Concerns", CCH International Tax, Nos. 54-55, December, 2010, p. 19.

Subsection 91(4.4) - Series of transactions

Articles

Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1230

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Subsection 91(4.5) - Exception — hybrid entities

Articles

Philippe Montillaud, Grant J. Russell, "Foreign Accrual Tax and Flow-through Entities", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1280

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Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, 1231-1232

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Paul L. Barnicke, Melanie Huynh, "Losing the FAT", Volume 21, Number 2, February 2013, 13 at 14

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Subsection 91(4.6)

Subsection 91(4.7) - Deemed ownership

Administrative Policy

26 April 2017 IFA Roundtable Q. 5, 2017-0691121C6 - Foreign tax credit Brazilian interest on equity

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Articles

Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4.1) 205

Paul L. Barnicke, Melanie Huynh, "Losing the FAT", Canadian Tax Highlights,Volume 21, Number 2, February 2013, 13 at 14.

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Subsection 91(5) - Amounts deductible in respect of dividends received

Administrative Policy

16 May 2018 IFA Roundtable Q. 3, 2018-0749171C6 - Interaction s.91(5) s.93.1(2)(d)(i)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 93.1 - Subsection 93.1(2) - Paragraph 93.1(2)(d) - Subparagraph 93.1(2)(d)(i) s. 93.1(2)(d)(i) limit does not reflect acquisition-debt interest deduction of LP 391
Tax Topics - Income Tax Regulations - Regulation 5900 - Subsection 5900(3) corporate-owned LP treated transparently to avoid a surplus anomaly re s. 91(5) dividend 220

16 November 2015 Internal T.I. 2015-0598491I7 - 91(5) & FAPI included per “old” 94(1)(c)(i)(C)

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December 1994 Tax Executives Institute Round Table, Q. XVI (943077)

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Articles

Bradley, "Foreign Affiliates: A Technical Update", 1990 Conference Report, c. 43

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Tax Topics - Income Tax Act - Section 93 - Subsection 93(1) 0

Paragraph 91(5)(b)

Administrative Policy

5 October 2001 External T.I. 2001-0093345 F - Déduction prévue à 91(5)

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