12 April 1995 External T.I. 9237145 F - Foreign Tax Credits - Consolidated Foreign Returns -- summary under Non-Business-Income Tax

Where a profitable Canadian subsidiary is permitted for U.S. tax purposes to be included in a consolidated group tax return, payments made by the Canadian subsidiary to its parent as compensation for the U.S. tax paid by the parent in respect of the Canadian subsidiary's share of the consolidated group income will not qualify as income or profits tax.