bien d'un fonds de placement non-résident

CONT: Subsection 94.1(1) of the [Income Tax] Act requires a notional amount to be included in income if a taxpayer holds an interest in an offshore investment fund property (OIFP). An OIFP is a share of the capital stock of, an interest in, or a debt of, a non-resident entity (other than a CFA [controlled foreign affiliate] of the taxpayer) or an interest in or a right or option to acquire such a share, interest, or debt if two conditions are satisfied.