Elaine Buzzell, "Distributions of Share Premium by Foreign Affiliates", Corporate Finance, Vol. XVII, No. 2, 2011, p. 1962

Summary Under

Tax Topics - Income Tax Act - Section 90 - Subsection 90(2)

Includes discussion of the treatment under the previous version of s. 90 of payments out of a share premium account as a dividend or shareholder benefit.

Summary Under

Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b)

Includes comparison with previous comfort letter proposals.

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Elaine Buzzell, "Distributions of Share Premium by Foreign Affiliates", Corporate Finance, Vol. XVII, No. 2, 2011, p. 1962