On 3 December 2021, the Supreme Court of Canada issued its judgment in the case Canada v. Loblaw Financial Holdings Inc., concerning the inclusion of foreign accrual property income (FAPI) of a Canadian company's subsidiary. The subsidiary was a bank licensed in Barbados and was initially funded by capital investments from its affiliates (related persons). The subsidiary earned income mostly by entering into investment transactions with arms' length persons (non-related persons). Considering…