Reference

Controlled Foreign Affiliate

Controlled Foreign Affiliate

Plain meaning

A foreign affiliate over which a Canadian taxpayer or related group has sufficient control under Canadian international tax rules.

Also called

CFA

Key points

  • Control is determined under detailed Income Tax Act rules, including ownership by related persons or groups.
  • A controlled foreign affiliate can give rise to FAPI inclusions for Canadian taxpayers.
  • The status matters for reporting forms, surplus calculations, and cross-border planning.
  • It is a subset of foreign affiliate concepts and should be analyzed with the specific ownership facts.

Why it comes up

Controlled foreign affiliate status can trigger FAPI inclusions, reporting, and surplus-account analysis.

News signals

foreign affiliates FAPI international tax reporting

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