Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 84
Page 415
... benefit or an advantage that has been conferred on a shareholder . The technical notes to Bill C - 139 indicated that " the words ' benefit or advantage ' in paragraph ( c ) [ item ( 3 ) ] are broad enough to include the payments ...
... benefit or an advantage that has been conferred on a shareholder . The technical notes to Bill C - 139 indicated that " the words ' benefit or advantage ' in paragraph ( c ) [ item ( 3 ) ] are broad enough to include the payments ...
Page 420
... benefit under subsection 15 ( 1 ) . He suggested further that if a benefit from an interest - free or a low - interest loan is to be included under subsection 15 ( 1 ) , the benefit must be conferred on the shareholder qua shareholder ...
... benefit under subsection 15 ( 1 ) . He suggested further that if a benefit from an interest - free or a low - interest loan is to be included under subsection 15 ( 1 ) , the benefit must be conferred on the shareholder qua shareholder ...
Page 424
... benefit from the purchase under an option and subsequent redemption of the stock of a subsidiary corporation . The treatment of the benefit depended on whether the option was received by virtue of employment according to the particular ...
... benefit from the purchase under an option and subsequent redemption of the stock of a subsidiary corporation . The treatment of the benefit depended on whether the option was received by virtue of employment according to the particular ...
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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