Section 93.4

Subsection 93.4(1)

FABI rules permit deferral (p.2)

Although Canadian-controlled private corporations (CCPCs) that earn investment income indirectly through a...

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Needed expansion of scope of FABI (pp. 10-11)

As noted by commentators, the definition of foreign accrual business income (FABI) should be...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		38
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		309
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Tax-Indifferent - Paragraph (c)		115
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (a)		269
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Lease		63
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

Reason for FABI rule (p. 2)

The “relevant tax factor” (RTF) proposals released on August 9, 2022 would have subjected all foreign accrual...

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