Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 75
Page 139
... payment was not to provide a bonus to the two employees . Both the size and the extraor- dinary nature of the inducement payments were emphasized by Grant DJ : The payment is nonrecurring and was made at a time that [ the purchaser ] ...
... payment was not to provide a bonus to the two employees . Both the size and the extraor- dinary nature of the inducement payments were emphasized by Grant DJ : The payment is nonrecurring and was made at a time that [ the purchaser ] ...
Page 140
... payments . Employee's Perspective An inducement payment in the hands of an employee may be characterized as either a benefit from the disposition of stock option rights or a settlement of damages from the employer's breach of a stock ...
... payments . Employee's Perspective An inducement payment in the hands of an employee may be characterized as either a benefit from the disposition of stock option rights or a settlement of damages from the employer's breach of a stock ...
Page 186
... payments between the parties . . . [ are ] fixed under the terms of the contract.39 To include currency swaps , a payment would be regarded as a fixed payment " provided it was variable only by virtue of fluctuations in exchange rates ...
... payments between the parties . . . [ are ] fixed under the terms of the contract.39 To include currency swaps , a payment would be regarded as a fixed payment " provided it was variable only by virtue of fluctuations in exchange rates ...
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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