Foreign Tax Credits: A Practical Guide for Practitioners

Foreign tax credits are a frequent source of frustration for tax advisors. The rules are complex, the consequences of error are significant, and the Canada Revenue Agency continues to closely scrutinize large and recurring foreign tax credit claims. This presentation focuses on the areas where practitioners most often encounter risk, uncertainty, and missed planning opportunities.

Key topics include:

a) A focused review of the most important elements of section 126 of the Income Tax Act

b) The distinction between business income tax and non-business income tax, and why the classification matters

c) The impact of the foreign tax credit rules on former residents of Canada

d) The section 110.5 election, which allows a corporation to increase taxable income to maximize deductible foreign tax credits without increasing certain other federal deductions or credits, while also increasing the corporation’s non-capital loss

e) Deductions available under section 20 for foreign taxes paid

f) The role of tax treaties in shaping foreign tax credit outcomes

g) Foreign tax credit planning strategies and common pitfalls

h) Selected CRA views and administrative guidance that provide insight into how claims are reviewed

i) The interaction between foreign tax credits and U.S. business structures

Summary

This session is designed to help practitioners move beyond mechanical compliance and develop a practical understanding of how foreign tax credit rules operate in real-world files. By highlighting high-risk areas, current CRA thinking, and targeted planning techniques, the presentation equips advisors to reduce reassessment exposure, strengthen foreign tax credit claims, and deliver more confident advice to clients with cross-border activities.

About this course

$170.00
2 CPD hours
November 26, 2026 - 1:00 PM ET

Instructor(s)

Alex Ghani

[email protected]

Partner

CPA CA, CGA, CPA (Texas)

Alex has close to 20 years of experience working in the accounting departments of large companies and as a public practitioner. Over the years, Alex helped many private clients with their tax structuring and estate planning needs. Alex also assists in Canadian and US tax compliance and various other tax related matters.

Alex is heavily involved in the tax community and is a member of the Canadian Tax Foundation (CTF) where he has published articles for the CTF and presented at various events for the CTF.

In addition, Alex has also presented at events for CPA Ontario, accounting groups and other industry specific events. He also facilitates the CPA Canada In-depth tax course.

Manu Kakkar

[email protected]

Manu has over 20 years of experience in taxation in both domestic and international, personal, and corporate taxation as well as expert witness reports and testimony. He is an award winning and prolific tax writer. His Master of Taxation thesis on butterfly reorganizations won 2 awards and was published in the Canadian Tax Journal. Manu has published and presented over 450 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 41 times in the Income Tax Act.