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Definition of FA
Examples of FA (1 - 7 Slides)
CFA (1 - 3)
Category of Income
What is FAPI?
What is not FAPI?
Tax Treatment of Types of Income
Different Taxing Entities
Partnership - Flow Through Vehicle
Taxing Opportunity
Tax Treatment of Types of Income After Re-structuring
Conclusion
Legal Notes and Disclaimer

FIE rules
Session Objective
Existing Rules (1 - 5 slides)
Proposed New Rules
Improvements of New Rules
What FIE Rules Apply?
Exempt Taxpayer
What is an FIE?
Exempt Interest (1 - 4)
Three Regimes for Income Inclusion
Imputed Income Method (1 - 6)
Accrual Method (1 - 5)
Mark-to-Market (1 - 4)
Conclusion
Legal Notes and Disclaimer

Dividends from Portfolio Investment (1 - 2 slides)
Dividends Paid by Foreign Affiliates (1 - 4)
Dividends Paid by Controlled Foreign Affiliates
Example - FAPI - For Individual
Dividends Paid by Controlled Foreign Affiliates
Example - FAPI - For Corporations
Forming a Canadian Holding Company (1 - 6)
Legal Notes and Disclaimer

Why Foreign Reporting?
Historic Event
Four Information Returns
Who Must File?
When Must Be Filed?
Examples of Foreign Affiliate (1 - 5 slides)
Examples of Controlled Foreign Affiliate (1 - 4)
T1135 - $100,000 Foreign Asset Rule
T1134 - Interest in Foreign Affiliates
T1141 - Transfer to Non-Resident Trust
T1142 - Distributions from Non-Resident Trust
Penalties (1 - 2)
Exception for Penalties
Questions and Answers (1 - 6)
Legal Notes and Disclaimer

How the Migration Rules Accomplish the Purpose
The New Rules (1 - 3 slides)
Impact of the New Rules
Tax Liability and Security
Bronfman Trust Influence (1 - 4)
How the New Migration Rules Work (1 - 4)
Tax Relief through Loss Carry-Back Provisions (1 - 4)
Reporting Requirements
Returning Non-Residents (1 - 4)
Residency (1 - 2)
Legal Notes and Disclaimer

Inheritance
Probate Planning
Gift Tax
Estate Planning - Estate Freeze (1 - 2 slides)
Estate Freeze Stage 1 (1 - 2)
Estate Freeze - Stages 2 -3 (1 - 2)
Estate Freeze - Family Trust (1 - 2)
Final Estate Planning - Will
Spouse Trust (1 - 2)
Other Ways to Avoid Will
Legal Notes and Disclaimer

Historical Origins
What is a Trust?
Characteristics of a Trust (1 - 2 slides)
Tax Treatment of a Trust (1 - 3)
Purpose of a Trust
Personal Trust
Inter Vivos Trust
Creating a Trust
Elements of a Trust
Using Offshore Trust for Tax Reasons
How a Trust is taxed (1 - 2)
How Offshore Trust is Caught by S. 94
Existing 94 Does not Apply
Specific Exclusions for S. 94
Tax Treatment of Inter Vivos Trust Under Existing S. 94 (1 - 2)
Conclusion
Legal Notes and Disclaimer

Purpose of Offshore Trust
How an Offshore Trust is Taxed (1 - 2 slides)
Deficiencies in Current Rules
History of New Offshore Trust Rules
Policy on New Offshore Trust Rules
Differences Between Old and New Offshore Trust Rules
New Offshore Trust Rules (1 - 16 slides)
How Canadian Beneficiaries are Taxed
Immigrant Trust
Legal Notes and Disclaimer

Session Objective Purpose of FAPI Rules Taxing Foreign Income What Rules Apply? Category of income What is FAPI? What is not FAPI? Conditions for FAPI Mechanics of Calculating FAPI (1 - 9 slides) Rules on Computation FAPI (1 - 4) Definitions: Participating Percentage Relevant Tax Factor Foreign Affiliate Equity Percentage Direct Equity Percentage Controlled Foreign Affiliate Meaning of Control Income of Active Business Income from Property Investment Business Qualifying Business FAPI Rules - Capital Gains and Losses Investment Business Business Other Than Active Business Income from Sale of Property - An Example: Irving Oil Income from Insurance and Reinsurance Income from Canadian Debt and Lease Obligations - An Example: Trustco Services Deemed Active Business Conclusion Legal Notes and Disclaimer