Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 80
Page 46
... equity in limited circumstances . For thin capitalization purposes , the calculation of equity on a gross basis allows a non - resident to receive credit for an equity contribution that is arguably made in form only . This artificial ...
... equity in limited circumstances . For thin capitalization purposes , the calculation of equity on a gross basis allows a non - resident to receive credit for an equity contribution that is arguably made in form only . This artificial ...
Page 47
... equity where the indebtedness may reasonably be considered to have arisen in connection with a contribution of equity by the non - resident . This kind of provision would leave in place the basic calculation of outstanding debt and equity ...
... equity where the indebtedness may reasonably be considered to have arisen in connection with a contribution of equity by the non - resident . This kind of provision would leave in place the basic calculation of outstanding debt and equity ...
Page 281
... equity limitation annually . Once this decision has been taken , it is clear that basing the limitation on equity immediately before the distribution , even for the year in which the distri- bution is made , is inappropriate . If the ...
... equity limitation annually . Once this decision has been taken , it is clear that basing the limitation on equity immediately before the distribution , even for the year in which the distri- bution is made , is inappropriate . If the ...
Other editions - View all
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