22 November 1991 Memorandum (Tax Window, No. 13, p. 9, ¶1608)

Provided that the primary and secondary affiliates are going concerns and the intercompany account has been charged with a number of offsetting items, the secondary affiliate will be considered to have paid the primary affiliate for the taxes where their amount has been booked to the intercompany account.

In the absence of persuasive evidence, charitable donations, political donations and penalties will not be considered to be deductible.