CRA rules that disposition of excluded property by foreign LP does not constitute FAPI

In 2014-0536661R3, the CRA issued an advance income tax ruling concerning a situation where a Canadian public company will consolidate property held by its controlled foreign affiliates and a wholly-owned foreign LP.

The CRA confirmed that a distribution of certain property from the foreign LP (consisting of a foreign mine and shares of a foreign corporation) to the controlled foreign affiliate partners would not constitute FAPI, provided that the properties constituted excluded property at the time of the disposition.