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IQ 1: General treatment
or “How to carry forward and use tax losses from CFCs and FIFs”
You could also call this:

“How you can carry forward CFC and FIF net losses to future tax years”

If you have an attributed CFC net loss or a FIF net loss, or both, you can carry it forward to a future tax year. This works in a similar way to carrying forward tax losses for companies. The rules for carrying forward these losses are found in [Section IA 5] and [subpart IB] of the Income Tax Act. These sections explain how to treat the net loss as if it were a tax loss component.

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Next up: IQ 2: Ring-fencing cap on attributed CFC net losses

or “Limits on using losses from foreign companies to reduce your income”
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Part I Treatment of tax losses
Attributed controlled foreign company net losses and foreign investment fund net losses

IQ 1BLosses carried forward to tax year

  1. An attributed CFC net loss or a FIF net loss or both may be carried forward to a tax year. Section IA 5 and subpart IB (which relate to the carrying forward of tax losses for companies) apply for the purposes of this subpart as if the net loss were a tax loss component.

Notes
  • Section IQ 1B: inserted (with effect on 1 April 2008), on , by section 61(1) of the Taxation (Consequential Rate Alignment and Remedial Matters) Act 2009 (2009 No 63).
  • Section IQ 1B: amended (with effect on 1 April 2020), on , by section 112(1) (and see section 112(2) for application) of the Taxation (Annual Rates for 2020–21, Feasibility Expenditure, and Remedial Matters) Act 2021 (2021 No 8).