21 October 2004 Internal T.I. 2004-0060131I7 - Characterization of Foreign Dividend -- summary under Subsection 90(1)

The distribution of amounts out of a share premium account of a foreign corporation that could have been declared and paid as a dividend under the foreign corporate law, but was not, should be characterized as a distribution of paid-in capital and not as a dividend.

Topics and taglines
Topic
Income Tax Act - s. 90(1)
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
322151
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
346330
Extra import data
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"field_legacy_header": "21 October 2004 Memorandum 2004-006013 [distribution out of share premium account]"
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