September 24, 2018

John Williams
President and Cheif Executive Officer
Domtar CORP
234 Kingsley Park Drive
Fort Mill, SC 29715

       Re: Domtar CORP
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 23, 2018
           Form 10-Q for the Fiscal Quarter Ended June 30, 2018
           Filed August 8, 2018
           File No. 001-33164

Dear Mr. Williams:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates and Policies, page 42

1.    We note your disclosure of the methodologies used to assess impairments
of goodwill and
      intangible assets on pages 43 to 46, and pages 62 to 64. We further note
your disclosure
      that during 2017, you recognized a goodwill impairment charge of $578
million,
      representing the entire amount of goodwill related to the Personal Care
reporting unit, due
      to growing competitive market pressures in the healthcare and retail
markets over the last
      year. However, it appears that you did not record any related impairments
of intangible
      assets.
 John Williams
Domtar CORP
September 24, 2018
Page 2


         Given the goodwill impairment of the Personal Care reporting unit,
explain to us, in
         reasonable detail, how you evaluated the intangible assets in your
Personal Care reporting
         unit for impairment. As part of your response, provide us a summary of
any cash flow
         testing you performed, together with an explanation of the basis for
all material
         assumptions made as part of the cash flow analysis. Additionally, your
response should
         address the basis for your conclusion that no impairment of intangible
assets was
         necessary given your disclosure on page 45 that the key estimates
supporting your cash
         flow projections for intangible assets are consistent with those
supporting your goodwill
         impairment analysis.
Form 10-Q for the Fiscal Quarter Ended June 30, 2018

Financial Statements
Note 1 - Basis of Presentation, page 8

2.       We note your disclosure of accounting policy related to revenue
recognition since January
         1, 2018 upon adoption of ASU 2014-09 "Revenue from Contracts with
Customers",
         including the statement that byproduct related revenues, such as sales
of excess power,
         waste paper and other wood related byproducts are recorded as a
reduction of
         manufacturing costs as they are incidental to the main
revenue-generating activities of the
         Company.

         Please tell us the byproduct sales amounts involved for each period
presented, and your
         basis for recording them as a reduction of manufacturing costs,
instead of as revenues,
         when they appear to be an output of your ordinary activities for which
you receive
         consideration in exchange.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759
or Lily
Dang, Staff Accountant, at (202) 551-3867with any questions.



FirstName LastNameJohn Williams                               Sincerely,
Comapany NameDomtar CORP
                                                              Division of
Corporation Finance
September 24, 2018 Page 2                                     Office of Natural
Resources
FirstName LastName