I have previously written about the “Worldwide trend of attacking the use of corporations as a way to reduce or defer taxation for individuals“. This is a continuation of this discussion. The purpose of this post is, primarily to focus on the proposed changes, to the taxation of passive income earned by Canadian Controlled Private Corporations (“CCPCs”).
Note that “CCPCs” often DO qualify as Controlled Foreign Corporations (“CFCs”) for Canadian residents who are U.S. citizens! In the past, this has meant that Canadian residents with U.S. citizenship have needed to be aware of the U.S. Subpart F income attribution rules. As a result, many people struggling with possible applicability of the U.S. “transition tax” (described here and here) are also experiencing tax changes in Canada.