Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
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Results 1-3 of 93
Page 268
... legislation regarding the deductibility of interest . The draft legislation responds to the Supreme Court of Canada's decision in the Bronfman Trust case . That decision cast doubt on the deduction of interest in certain circumstances ...
... legislation regarding the deductibility of interest . The draft legislation responds to the Supreme Court of Canada's decision in the Bronfman Trust case . That decision cast doubt on the deduction of interest in certain circumstances ...
Page 269
... legislation dealing with the deduction of interest . ' This legislation has been eagerly anticipated by the Canadian tax community for several years . This article examines the draft legislation from both a technical and a policy ...
... legislation dealing with the deduction of interest . ' This legislation has been eagerly anticipated by the Canadian tax community for several years . This article examines the draft legislation from both a technical and a policy ...
Page 272
... legislation has two objectives : first , to provide explicit legislative rules authorizing the application of Rev- enue Canada's administrative rules concerning interest deductibility after the Bronfman Trust decision , and second , to ...
... legislation has two objectives : first , to provide explicit legislative rules authorizing the application of Rev- enue Canada's administrative rules concerning interest deductibility after the Bronfman Trust decision , and second , to ...
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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