In 2015-0572461I7, the CRA indicated that a Canadian resident individual who holds shares in disregarded LLCs through a Canadian LP and a US LP that has elected to be treated as a corporation for US tax purposes is entitled to a deduction under subsection 20(11) and/or subsection 20(12) of the Income Tax Act (Canada) for the US taxes paid by the US LP, provided that all requirements of these provisions are otherwise met. This appears to be a reversal of the CRA’s former administrative position that subsection 20(12) applies on a source-by-source basis.