24 August 1990 Income Tax Severed Letter AC59478 - Computation of Income from an Active Business of a Foreign Affiliate

By services, 22 July, 2022
Official title
Computation of Income from an Active Business of a Foreign Affiliate
Language
English
Document number
Citation name
AC59478
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
658164
Extra import data
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"field_release_date_new": "1990-08-24 08:00:00",
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Main text

24(1)

                                       5-9478
24(1)                                  O. Laurikainen
                                       (613) 957-2129

Attention: 19(1)

AUG 24 1990

Dear Sirs:

Re: Subparagraph 95(2)(a)(ii) of the Income Tax Act (the "Act")

This is in response to your letter of January 24, 1990. Provided an amount paid or payable to a foreign affiliate ("FA1") of a taxpayer by another foreign affiliate ("FA2") of a taxpayer is deductible in computing the amount prescribed to be FA2's earnings or loss from an active business other than a business carried on in Canada, it is our view such an amount would be included in the computation of FA1's income from an active business pursuant to subparagraph 95(2)(a)(ii) of the Act.

We trust this is the information you require.

Yours truly,

for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch