• What if a CFC fails the active income test?

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    If a CFC fails the active income test, amounts that would be assessable if the CFC were a resident are included in attributable income to the extent they represent the following:

    • adjusted tainted income derived by the CFC directly
    • adjusted tainted income derived by the CFC indirectly as a partner in a partnership
    • trust amounts arising directly
    • trust amounts arising indirectly because the CFC is a partner in a partnership, or
    • FIF income derived by the CFC directly or indirectly as a partner in a partnership.
    Last modified: 05 Dec 2006QC 18000