20 July 2011 Internal T.I. 2011-0397961I7 - Aggregate Investment Income -- summary under Aggregate Investment Income

CRA indicated that an amount included in income of a corporation pursuant to s. 94.1(1) would be considered to be from a source that is a property (and, thus, would be included in the definition of "aggregate investment income" in s. 129(4)) notwithstanding that, unlike the income inclusion under s. 91(1) regarding FAPI, such income was not deemed to be in respect of a share owned by the taxpayer of the capital stock of a foreign affiliate of the taxpayer.