Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 76
Page 24
... direct investment , non - tax factors generally supersede tax considerations in the initial decision to invest.88 However , taxation is one of the primary considerations in the decision to reinvest earnings in the source country or ...
... direct investment , non - tax factors generally supersede tax considerations in the initial decision to invest.88 However , taxation is one of the primary considerations in the decision to reinvest earnings in the source country or ...
Page 26
... direct . The preferred test has instead been a share ownership test of 10 or 25 percent of a particular class , all outstanding shares , and / or the relative fair market value of all outstand- ing shares . These types of ownership ...
... direct . The preferred test has instead been a share ownership test of 10 or 25 percent of a particular class , all outstanding shares , and / or the relative fair market value of all outstand- ing shares . These types of ownership ...
Page 33
... direct investment for the purpose of subsection 18 ( 4 ) . The former definition might be amended to approximate more closely foreign direct investment and its unique economic characteristics . If the definition is too broad , the thin ...
... direct investment for the purpose of subsection 18 ( 4 ) . The former definition might be amended to approximate more closely foreign direct investment and its unique economic characteristics . If the definition is too broad , the thin ...
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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