Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 45
Page 19
... regulations proposed by the Treasury Department in 198067 that was with- drawn in 1983 before ever being enacted . Neither the case law nor the Treasury regulations have been concerned specifically with debt of a resident corporation ...
... regulations proposed by the Treasury Department in 198067 that was with- drawn in 1983 before ever being enacted . Neither the case law nor the Treasury regulations have been concerned specifically with debt of a resident corporation ...
Page 405
... regulation 4801. For foreign property purposes , regulation 5000 ( 1 ) prescribes a trust that meets all the conditions in the Act and regulations to qualify as a mutual fund trust , with the exception of the minimum beneficiary and ...
... regulation 4801. For foreign property purposes , regulation 5000 ( 1 ) prescribes a trust that meets all the conditions in the Act and regulations to qualify as a mutual fund trust , with the exception of the minimum beneficiary and ...
Page 528
... regulations recently released by the Treasury Department . ' These regulations attempt , in certain cases , to bifurcate any instrument or security in which any element of the interest or principal obligations is contingent . The ...
... regulations recently released by the Treasury Department . ' These regulations attempt , in certain cases , to bifurcate any instrument or security in which any element of the interest or principal obligations is contingent . 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