Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 84
Page 143
... taxpayer's arguments . A clause of the option agreement provided that the option was to " cease and terminate and be of no further force or effect whatsoever''107 in the event of the employee's discharge , and the memorandum sent to the ...
... taxpayer's arguments . A clause of the option agreement provided that the option was to " cease and terminate and be of no further force or effect whatsoever''107 in the event of the employee's discharge , and the memorandum sent to the ...
Page 144
... taxpayer's income from an office or an employment pursuant to paragraph 6 ( 1 ) ( a ) . Rip TCJ stated that " if an ... taxpayer to characterize inducement payments as damages arising from a breach of a stock option agreement . Moreover ...
... taxpayer's income from an office or an employment pursuant to paragraph 6 ( 1 ) ( a ) . Rip TCJ stated that " if an ... taxpayer to characterize inducement payments as damages arising from a breach of a stock option agreement . Moreover ...
Page 477
... taxpayer , denying the deduction of compound interest . The taxpayer's appeal to the Exchequer Court was dismissed . 18 The issue before the Supreme Court was whether the compound interest deducted by the taxpayer in each of the years ...
... taxpayer , denying the deduction of compound interest . The taxpayer's appeal to the Exchequer Court was dismissed . 18 The issue before the Supreme Court was whether the compound interest deducted by the taxpayer in each of the years ...
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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