Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 45
Page 281
... 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 limitation ...
... 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 limitation ...
Page 285
... limitation is a one - time test , its significance is limited . In effect , the limitation restricts the amount allocated to a property or expenditure to the cost of the property or the amount of the expenditure , since that represents ...
... limitation is a one - time test , its significance is limited . In effect , the limitation restricts the amount allocated to a property or expenditure to the cost of the property or the amount of the expenditure , since that represents ...
Page 286
... limitation may often be simpler than the basic limitation . Although the alternative limitation is sub- ject to an overall limitation , namely , the taxpayer's equity , that limitation is applied only once - immediately before the ...
... limitation may often be simpler than the basic limitation . Although the alternative limitation is sub- ject to an overall limitation , namely , the taxpayer's equity , that limitation is applied only once - immediately before 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