In 2014-0536581I7, the CRA was asked why the so-called fresh start rule for foreign affiliates (s. 95(2)(k) & (k.1)) applies only to income from a foreign affiliate’s business and not to the affiliate’s income from property. In response, the CRA said that “the threshold amount of activity that is required to cause any corporation (including a FA) to be considered to be carrying on business is extremely low”. This general principle (among others) will be discussed at the upcoming annual conference of the Canadian Tax Foundation in Vancouver on December 1, 2014.