Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 79
Page 190
... PROPOSED AMENDMENTS TO THE DEEMED REALIZATION RULES FOR TRUSTS Kathryn B. Hawkesworth ** In the light of the proposed changes to the deemed realization rules for trusts , this article provides a framework in which to review existing ...
... PROPOSED AMENDMENTS TO THE DEEMED REALIZATION RULES FOR TRUSTS Kathryn B. Hawkesworth ** In the light of the proposed changes to the deemed realization rules for trusts , this article provides a framework in which to review existing ...
Page 191
... proposed amendments specifically address some of the planning opportunities that have been suggested in the past . The new rules allow an election to be made in certain restricted circumstances to defer the deemed disposition of trust ...
... proposed amendments specifically address some of the planning opportunities that have been suggested in the past . The new rules allow an election to be made in certain restricted circumstances to defer the deemed disposition of trust ...
Page 195
... proposed anti - avoidance rule outlined in proposed paragraph 104 ( 5.5 ) ( b ) : 1 ) the designated contributor , 2 ) the spouse or former spouse of the designated contributor , and 3 ) the grandparent , parent , sibling , child ...
... proposed anti - avoidance rule outlined in proposed paragraph 104 ( 5.5 ) ( b ) : 1 ) the designated contributor , 2 ) the spouse or former spouse of the designated contributor , and 3 ) the grandparent , parent , sibling , child ...
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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