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1(2)(i) a taxpayer's election to treat a FIE as a foreign affiliate would be rendered invalid unless the taxpayer can demonstrate to CRA within 60 days of a written demand by the Minister that the FAPI income of the entity has been properly reported. Along with the enhanced FAPI, Object-Fax version 6. To the extent that the shares of CFA2 are excluded property but residual FAPI remains in the entity, the current foreign affiliate rules would attribute the FAPI to CANCO. |
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