Summary UnderTax Topics - Income Tax Act - Section 90 - Subsection 90(14) Narrowness of repayment rule (p. 251) There are situations in which an upstream loan may cease to represent a synthetic distribution from a...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Summary UnderTax Topics - Income Tax Act - Section 90 - Subsection 90(9) Narrowness of s. 90(11) (p. 261) Subsection 90(11) incorporates only the surplus of the downstream foreign affiliates that are directly or...The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access. Email this Content