Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 78
Page 292
... loan or where subsection 80.4 ( 3 ) applies to the loan . Subsection 80.4 ( 3 ) provides that subsections 80.4 ( 1 ) and ( 2 ) do not apply where an employee or shareholder loan is made on arm's - length terms , determined at the time of ...
... loan or where subsection 80.4 ( 3 ) applies to the loan . Subsection 80.4 ( 3 ) provides that subsections 80.4 ( 1 ) and ( 2 ) do not apply where an employee or shareholder loan is made on arm's - length terms , determined at the time of ...
Page 420
... loans . The loan received by the shareholders was divided into two components . One part of the loan , traceable to the corporation's operating funds , did not provide an assessed benefit ; the other part of the loan , made from funds ...
... loans . The loan received by the shareholders was divided into two components . One part of the loan , traceable to the corporation's operating funds , did not provide an assessed benefit ; the other part of the loan , made from funds ...
Page 423
... loan was excluded under the provisions of subsection 15 ( 2 ) , ( e.g. , where it was a bona fide loan to an officer of the company to purchase a house with adequate provision for repayment ) , and where the differential in interest ...
... loan was excluded under the provisions of subsection 15 ( 2 ) , ( e.g. , where it was a bona fide loan to an officer of the company to purchase a house with adequate provision for repayment ) , and where the differential in interest ...
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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