subpart f income

This is our main tax information forum which deals with topics concerning Canadians living and working in the U.S., U.S. citizens contemplating working in Canada, and all aspects of Canadian and U.S. income tax and related adminstrative issues.

Moderator: Mark T Serbinski CA CPA

Post Reply
mtnman
Posts: 37
Joined: Thu Nov 15, 2012 2:06 pm
Location: Lethbridge, Ab

subpart f income

Post by mtnman »

Can anybody tell me whether the gain on sale of Canadian real property by a Controlled Foreign Corporation is subpart f income to the corporations US shareholders.


Thanks
JGCA
Posts: 754
Joined: Thu Nov 18, 2010 3:05 pm
Location: Montreal, QC Canada

Post by JGCA »

If the gain on the sale is included in the income of the feoreign sub then its included in sub f income to the parent . Unless its income exempt under treaty gains on sale of any property have to be included in the corp income.
JG
Post Reply