• What if a CFC passes the active income test?

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    If a CFC passes 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:

    • FIF income derived by the CFC directly or indirectly as a partner in a partnership
    • trust amounts arising to the CFC directly, or
    • trust amounts arising to the CFC indirectly because the CFC is a partner in a partnership.

    These amounts are explained in sections 5 and 6. Any other income is notional exempt income.

    Diagram of amounts taken into account

    Trust and FIF income derived directly or indirectly via a partnership are always included; tainted income derived directly or indirectly via a partnership is only included if the CFC fails the active income test; other income is not included.

    Last modified: 05 Dec 2006QC 18000