Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 73
Page 233
... taxation year of the reorganization , and may also result in capital tax savings in each subsequent taxation year . " SAMPLE CORPORATE STRUCTURE Unless otherwise stated , the fact situation of the corporate structure referred to in the ...
... taxation year of the reorganization , and may also result in capital tax savings in each subsequent taxation year . " SAMPLE CORPORATE STRUCTURE Unless otherwise stated , the fact situation of the corporate structure referred to in the ...
Page 243
... taxable PUC will be transferred to Parentco , and Parentco will be liable for capital tax on Subco's taxable PUC in its December 31 , 1991 taxation year . This same taxable PUC had been taxed one month earlier in Subco . If Subco must ...
... taxable PUC will be transferred to Parentco , and Parentco will be liable for capital tax on Subco's taxable PUC in its December 31 , 1991 taxation year . This same taxable PUC had been taxed one month earlier in Subco . If Subco must ...
Page 244
... taxation year is its paid - up capital as it stood at the close of the taxation year . " Therefore , Subco will avoid having to pay capital tax if it is wound up before its 1991 taxation year - end . Subco will also not have an LCT ...
... taxation year is its paid - up capital as it stood at the close of the taxation year . " Therefore , Subco will avoid having to pay capital tax if it is wound up before its 1991 taxation year - end . Subco will also not have an LCT ...
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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