Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 88
Page 162
... APPEAL ON GAAPS AND GAAR The Queen v . Friedberg 92 DTC 6031 Late last year , the Court of Appeal delivered reasons for judgment in the Friedberg appeal . The case raised two quite distinct tax - planning issues , one dealing with gifts ...
... APPEAL ON GAAPS AND GAAR The Queen v . Friedberg 92 DTC 6031 Late last year , the Court of Appeal delivered reasons for judgment in the Friedberg appeal . The case raised two quite distinct tax - planning issues , one dealing with gifts ...
Page 170
... Appeal is also supported by subsection 165 ( 5 ) of the Act , which states that a reassessment issued by Revenue Canada in response to a notice of objection is not invalid by reason of its being issued outside the three- or four - year ...
... Appeal is also supported by subsection 165 ( 5 ) of the Act , which states that a reassessment issued by Revenue Canada in response to a notice of objection is not invalid by reason of its being issued outside the three- or four - year ...
Page 719
... appeal are presumed to be true , and make a direction regarding the hearing fee , ( c ) allow the appeal if the facts alleged in the notice of appeal entitle the appellant to the relief sought , or ( d ) give such other direction as is ...
... appeal are presumed to be true , and make a direction regarding the hearing fee , ( c ) allow the appeal if the facts alleged in the notice of appeal entitle the appellant to the relief sought , or ( d ) give such other direction as is ...
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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