![]() ![]() Additional disclosure and tax consequences apply to a Canadian entity from ownership of a CFA. When the combination of shares held by a Canadian entity, its related parties and up to four arm’s length Canadian entities and their related parties results in control of a FA, the FA is considered a controlled foreign affiliate (“CFA”). Limited Liability Corporation is considered a corporation for Canadian tax purposes, even though it may not be treated as such for U.S. It is important to note that for Canadian tax purposes, a foreign entity may be considered a corporation despite not being considered as such for foreign tax purposes. ![]() ![]() As the whirlwind of 2020 ends and 2021 starts, this publication serves as a reminder that there are new deadlines for Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates, which will apply to tax years beginning in 2020.įorm T1134 is to be completed when a Canadian individual, corporation, trust or, if applicable, partnership (individually, a “Canadian entity”), directly or indirectly, owns at least 10 per cent of any class of the shares of a foreign corporation (“foreign affiliate (FA)”). ![]()
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