Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 71
Page 178
... referred to as " the 1991 interest rate document " ) . 5 See United Kingdom , Board of Inland Revenue , A Consultative Document : Tax Treatment of Foreign Exchange Gains and Losses ( London : the board , March 14 , 1989 ) ( herein referred ...
... referred to as " the 1991 interest rate document " ) . 5 See United Kingdom , Board of Inland Revenue , A Consultative Document : Tax Treatment of Foreign Exchange Gains and Losses ( London : the board , March 14 , 1989 ) ( herein referred ...
Page 339
... referred to as " the Act " ) . Unless otherwise stated , statutory references in this article are to the Act . 2 Subsequently referred to as " paid - up capital . " Paid - up capital for corporate law purposes and stated capital are ...
... referred to as " the Act " ) . Unless otherwise stated , statutory references in this article are to the Act . 2 Subsequently referred to as " paid - up capital . " Paid - up capital for corporate law purposes and stated capital are ...
Page 721
... referred to in Article 6 and situated in the other Con- tracting State may be taxed in that other State . 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an ...
... referred to in Article 6 and situated in the other Con- tracting State may be taxed in that other State . 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an ...
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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