Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 82
Page 130
... effect is a subjective one . The disadvantage of attempting to amend an award with retroactive effect in order to vary the tax consequences to the recipients is that the employees would be subject to interest on any taxes owing and ...
... effect is a subjective one . The disadvantage of attempting to amend an award with retroactive effect in order to vary the tax consequences to the recipients is that the employees would be subject to interest on any taxes owing and ...
Page 237
... effect of the wind - up and the paragraph 88 ( 1 ) ( d ) designation on the balance sheet of Parentco is illustrated in table 2 . The increased Ontario capital tax and LCT liability of $ 195,000 and $ 130,000 , respectively , will be ...
... effect of the wind - up and the paragraph 88 ( 1 ) ( d ) designation on the balance sheet of Parentco is illustrated in table 2 . The increased Ontario capital tax and LCT liability of $ 195,000 and $ 130,000 , respectively , will be ...
Page 346
... effect on stated capital or on any of the adjustments . Therefore , it would also have no effect on paid - up capital . Revenue Canada takes the position that such an amendment does not trigger a disposition for tax purposes of the ...
... effect on stated capital or on any of the adjustments . Therefore , it would also have no effect on paid - up capital . Revenue Canada takes the position that such an amendment does not trigger a disposition for tax purposes of the ...
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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