Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
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Results 1-3 of 80
Page 49
... basis . Such an approach assigns relative weight to all outstanding debts owed to specified non - residents , the relative weight being based on the number of days in the year during which the indebtedness is outstanding . For instance ...
... basis . Such an approach assigns relative weight to all outstanding debts owed to specified non - residents , the relative weight being based on the number of days in the year during which the indebtedness is outstanding . For instance ...
Page 180
... basis - when foreign currency proceeds are actually con- verted into sterling ; settled transaction basis - when the transaction is settled by cash pay- ment ; and translation basis - when assets and liabilities that arise from the ...
... basis - when foreign currency proceeds are actually con- verted into sterling ; settled transaction basis - when the transaction is settled by cash pay- ment ; and translation basis - when assets and liabilities that arise from the ...
Page 188
... basis in their financial statements , presumably because this basis would not normally be consistent with generally accepted accounting principles.2 The document states that a company that uses a mark - to - market basis in its ...
... basis in their financial statements , presumably because this basis would not normally be consistent with generally accepted accounting principles.2 The document states that a company that uses a mark - to - market basis in its ...
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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