Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 80
Page 203
... distribution , but also whether the purposes for which the trust was established are met by the proposed distribution . Whether trustees can distribute trust assets to beneficiaries before the deemed disposition date of the trust and in ...
... distribution , but also whether the purposes for which the trust was established are met by the proposed distribution . Whether trustees can distribute trust assets to beneficiaries before the deemed disposition date of the trust and in ...
Page 274
... distribution would not be considered to have been used directly for the purpose of earning income . For corporations , a " distribution " is defined to be any dividend or pay- ment on the redemption , acquisition , or cancellation of a ...
... distribution would not be considered to have been used directly for the purpose of earning income . For corporations , a " distribution " is defined to be any dividend or pay- ment on the redemption , acquisition , or cancellation of a ...
Page 275
... distribution should therefore qualify for deduction under paragraph 20 ( 1 ) ( e ) . The relationship between proposed subsection 20.1 ( 1 ) and subsection 20 ( 3 ) is worth noting . The issue is whether subsection 20.1 ( 1 ) applies ...
... distribution should therefore qualify for deduction under paragraph 20 ( 1 ) ( e ) . The relationship between proposed subsection 20.1 ( 1 ) and subsection 20 ( 3 ) is worth noting . The issue is whether subsection 20.1 ( 1 ) applies ...
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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