Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 62
Page 129
... agreement null and void , as would be the case with a true condition precedent . In Revenue Canada's view , a prohi- bition on the transfer of the shares also does not preclude a finding that title to the shares has been acquired for ...
... agreement null and void , as would be the case with a true condition precedent . In Revenue Canada's view , a prohi- bition on the transfer of the shares also does not preclude a finding that title to the shares has been acquired for ...
Page 143
... agreement amending the stock option agreement and to surrender the options , and found that there had been no breach of the stock option agreement by the employer . This rejection was made in the face of evidence that supported the ...
... agreement amending the stock option agreement and to surrender the options , and found that there had been no breach of the stock option agreement by the employer . This rejection was made in the face of evidence that supported the ...
Page 144
agreement cancelling his options , he disposed of his rights under the stock option agreement . Rip TCJ further held that even if the lump sum received by the taxpayer represented damages for the breach of the stock option agreement and ...
agreement cancelling his options , he disposed of his rights under the stock option agreement . Rip TCJ further held that even if the lump sum received by the taxpayer represented damages for the breach of the stock option agreement and ...
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Common terms and phrases
actionnaires actions amended amount apply assets autre avantage bénéficiaires beneficiary benefit biens Canadian Tax Foundation canadienne capital cost allowance capital gains capital tax choix contribuable corporate tax corporation cible cost Cour coût d'actions d'une debt déduction deduction of interest deemed dégel dépenses distribution dividend droit employee employee stock option equity été expenditure fait federal fiducie Finance fiscal foreign foreign direct investment funds Ibid income tax intérêts investment issue l'acheteur l'alinéa l'article l'impôt legislation loan loss million montant Newco Ontario opération paid-up capital paragraph Parentco payable payment percent person perte pourrait profits proposed provincial provision reçu règles Report resident respect Revenue Canada rules shareholder shares société specific specified non-residents stare decisis stock option Subco subsection supra footnote Tax Conference Tax Court tax treaties taxable taxation taxpayer thin capitalization titre Toronto transaction transfer treaty trust valeur vertu withholding tax