FAPI

(redirected from Foreign Accrual Property Income)
AcronymDefinition
FAPIFonds d'Aide à la Promotion de l'Invention et de l'Innovation (French: Assistance Fund for the Promotion of Invention and Innovation)
FAPIForeign Accrual Property Income (tax term)
FAPIFlorida Association of Private Investigators
FAPIFemto Application Platform Interface (industry software initiative)
FAPIFellow of the Australian Property Institute
FAPIFunctional Auditory Performance Indicators (auditory assessment)
FAPIFamily Application Programmer Interface
FAPIFederasi Asosiasi Perasuransian Indonesia (Indonesian: Federation of Indonesian Insurance Associations)
References in periodicals archive ?
In many cases, a controlled foreign affiliate may earn gross revenue from property in a particular taxation year, but that gross revenue may not result in foreign accrual property income to the taxpayer because the gross revenue arose from an active business carried on by the controlled foreign affiliate (including from activities that are deemed to be an active business under paragraph 95(2) (a)).
re-introducing previously proposed rules to ensure an appropriate income inclusion for stub-year foreign accrual property income on dispositions of foreign affiliate shares;
A separate information return, must be filed for each foreign affiliate and must include information with respect to the affiliate's corporate structure, equity interest held by the Canadian taxpayer, financial statements and foreign accrual property income. Also, if a taxpayer receives a dividend from the affiliate, then further details must be provided.
the taxation of Canadian corporations with foreign affiliates (including changes to ensure that various rules apply appropriately to structures that include partnerships, changes to certain of the base-erosion rules, and new rules to ensure an appropriate income inclusion for stub-year foreign accrual property income on dispositions of foreign affiliate shares);
In paragraph 11.108 we showed how the foreign accrual property income rules continue to be exploited.
Even if the CFA2 shares were to retain their excluded property status, any foreign accrual property income (FAPI) earned by CFA2 would be taxable in Canada.
She also noted that some Canadian taxpayers have entered into transactions with foreign affiliates that erode the tax base and recommended that the Department of Finance reassess the rules relating to interest deductibility, foreign accrual property income, and taxable dividends.
In many cases, the proposal (in proposed subsection 93(1.4) of the Act) would have deemed the shares transferred to be outside the definition of"excluded property." Consequently, any gain realized by an affiliate on the disposition of the shares (in excess of the amount eligible for a section 93 deemed dividend election) would create foreign accrual property income (FAPI), which is taxed immediately in the hands of the Canadian shareholder if the affiliate is a controlled foreign affiliate.
The Income Tax Act (Canada) (the Act) (3) contains two primary anti-deferral regimes to prevent Canadian taxpayers from earning "passive" income offshore: the foreign accrual property income (FAPI) rules, (4) and the FIE Rules, which replace and significantly expand the offshore investment fund property (OIFP) (5) rules.
As important, the letter said, the scope, nature, and far-reaching effect of the proposed legislation go far beyond the stated purpose of combating "tax avoidance." Indeed, TEI said, the proposed legislation implements a comprehensive new regime for taxing indirect foreign investment and substantially overlap the foreign accrual property income (FAPI) system of taxing foreign affiliates.
The Canadian Income Tax Act (Canada) (the Act) addresses this concern primarily through two anti-deferral regimes: (2) the foreign accrual property income (FAPI) rules, (3) and the offshore investment fund property (OIFP) (4) rules.
In many cases in which a specific rollover provision (subsection 88(3) or paragraphs 95(2)(c), (d) or (e)) does not apply, the proposal (in proposed subsection 93(1.4) of the Act) would deem the shares transferred to be outside the definition of "excluded property." Consequently, any gain realized by an affiliate on the disposition of the shares (in excess of the amount eligible for a section 93 deemed dividend election) would create FAPI (foreign accrual property income), which is taxed immediately in the hands of the Canadian shareholder if the affiliate is a controlled foreign affiliate.