The New 95(2)(F.1) Carve-Out Rule - Election Deadline Approaching
Geoffrey S. Turner
Davies Ward Phillips & Vineberg LLP
January 7, 2010
The author discusses the newly enacted "carve-out" rule in paragraph 95(2)(f.1) of the Income Tax Act (Canada) that can exclude certain gains and losses and FAPI amounts accrued in a foreign affiliate of a "designated acquired corporation" before an acquisition of control.
Number of Pages in PDF File: 7
Keywords: foreign affiliate, FAPI, designated acquired corporation
JEL Classification: H25working papers series
Date posted: May 13, 2010
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