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Tax Interpretations
Canadian tax interpretations and transactional implications
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CRA reverses a Code s. 338(h)(10) step-up of goodwill so as to boost exempt earnings of a U.S. foreign affiliate – but finds that there was no corresponding boost to safe income on hand of a Canco shareholder
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(Your name) has forwarded "CRA reverses a Code s. 338(h)(10) step-up of goodwill so as to boost exempt earnings of a U.S. foreign affiliate – but finds that there was no corresponding boost to safe income on hand of a Canco shareholder" - Tax Interpretations
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