Section 93.4

Subsection 93.4(1)

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

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.