Arda Minassian, Kara Ann Selby, "Computation of Surplus Accounts", 2002 Conference Report, (CTF), c. 43

Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings
Business in multiple countries (p. 43:6)

If a foreign affiliate carries on a business in multiple countries, the earnings definition may not...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2) - Paragraph 5907(2)(j)

The underlying principle of the regulation 5907(2) adjustments is to determine the amount of assets available to repatriate surplus. Permanent...

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