| 24(1) | File No. 900897 |
| O. Laurikainen | |
| (613) 957-2129 |
June 1, 1990
Dear Sirs:
Re: German Corporation Tax Credit
This is further to our letter of May 23, 1990 and in response to your letter of May 25, 1990.
In our view, once the taxpayer's German income tax liability with respect to a dividend from a German corporation is determined and paid such payment of tax is recognized as a foreign tax paid for the purposes of section 126 of the Income Tax Act. It does not matter whether such payment is accomplished by the application of the German corporation tax credit or by a cash payment or a combination of both types of payments.
We trust that the above is the information you require.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch