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FAPI |
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Recently, however, the CRA has confirmed that it is changing its assessing practice for purposes of the FAPI regime3 such that a controlled foreign affiliate will now meet the "more than five full-time employees" exclusion in the investment business definition where the controlled foreign affiliate employs five full-time employees and one part-time employee in the active conduct of the business. TEI recommends that the exemption for dividends from active business income be expanded without tightening the FAPI rules and without adding limitations on the deductibility of expenses, such as interest, incurred in Canada in support of foreign business investments. In effect, where a taxable capital gain constituted FAPI that was included in the income of a Canadian shareholder, the currency rule specified that it must be computed in Canadian dollars. |
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