Canadian Tax Journal, Volume 43, Issues 5-6Canadian Tax Foundation., 1995 - Taxation |
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Advance Pricing Agreements amendments amount Appeal apply approach assets basis budget business in Canada Canadian Tax Foundation Canadian Tax Journal canadienne capital cost allowance capital gains carrying on business changes contracting corporation cost countries Cour Court of Canada debt deemed Department of Finance depreciation disposition dividends earned economic entreprise au Canada été être exempt expectation of profit FAPI FCTD federal fiscal foreign affiliate Ibid included Income Tax Act interpretation investment issue l'Association l'impôt legislation limited non-resident OECD model paragraph partner partnership payments percent person provinces provisions Report resident respect result Revenue Canada RRSP rules shareholders shares société statutory subsection supra footnote Supreme Court tax avoidance Tax Conference tax convention tax policy tax rates tax reform tax system tax treaty taxable taxation in Canada taxpayer tion Toronto transactions transfer pricing trust United United Kingdom withholding tax