Section 113

Subsection 113(1) - Deduction in respect of dividend received from foreign affiliate

Administrative Policy

2004 Miscellaneous 2004-0103111R3 - Foreign affiliates; indirect payment

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93 C.R. - Q. 59

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Articles

Kenneth Snider, "Selecting the Foreign Business Entity: A Review of the Canadian Tax Treatment of U.S. Taxes Paid By a Member (Shareholder) of a U.S. Limited Liability Corporation", International Tax Planning, 2002 Canadian Tax Journal, Vol. 50 No. 2, p. 705.

Lanthier, "Emerging Income Tax Issues: Public Service 2,000, International Finance Companies, and U.S. Limited Liability Companies", 1993 Conference Report, pp. 3:19 - 29

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Paragraph 113(1)(a)

Administrative Policy

15 May 2019 IFA Roundtable Q. 9, 2019-0798761C6 - Surplus Documentation

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2.2) failure by Canco to prepare surplus accounts precludes late- filed Reg. 5901(2)(b) election 221

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1049)

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81 C.R. - Q.12

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Articles

Nathan Boidman, Michael N. Kandev, "Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing by Canadian MNEs", Tax Notes International, February 11, 2019, p. 623

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Lanthier, "Foreign Holding Companies and Finance Vehicles: An Update", 1990 Conference Report, c. 42

Paragraph 113(1)(a.1)

Articles

Sandra Slats, David Burns, "Canada Considers New Rules on Repatriation", Tax Notes International, Vol 63, No. 9, 29 August 2011, p. 641

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(4) 2

Paragraph 113(1)(c)

Administrative Policy

11 June 2013 STEP Roundtable, 2013-0480321C6 - 2013 STEP Question 6 US LLCs - FAPI, FAT and FTCs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) deduction for US tax on LLC income which also is FAPI 157
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Tax 316

Articles

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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