OrbitaxSupreme Court of Canada Upholds Appeals Court Judgment on Eligibility for Exclusion of Income Earned by Foreign Subsidiary Bank
|Approved Changes|Canada
On 3 December 2021, the Supreme Court of Canada issued its judgment in the case Canada v. Loblaw Financial Holdings Inc., concerning the inclusion of foreign accrual property income (FAPI) of a Canadian company's subsidiary. The subsidiary was a bank licensed in Barbados and was initially funded by capital investments from its affiliates (related persons). The subsidiary earned income mostly b…
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