Canadian Tax Journal, Volume 40, Issues 1-3Canadian Tax Foundation., 1992 - Taxation |
From inside the book
Results 1-3 of 78
Page 176
... transfer had occurred . In reaching his conclusion , however , Mr. Justice Jerome may not have adequately addressed ... transfer all the property of a deceased does not , in itself , transfer the property . Presumably the operation of a ...
... transfer had occurred . In reaching his conclusion , however , Mr. Justice Jerome may not have adequately addressed ... transfer all the property of a deceased does not , in itself , transfer the property . Presumably the operation of a ...
Page 205
... transfer to the capital beneficiary trust assets that are charged with the payment of life income to an income beneficiary.45 In the Wilson case , it was held that the amount payable to the income beneficiary by the capital beneficiary ...
... transfer to the capital beneficiary trust assets that are charged with the payment of life income to an income beneficiary.45 In the Wilson case , it was held that the amount payable to the income beneficiary by the capital beneficiary ...
Page 825
... transfer of property to it ; ( 2 ) the operation of the entity ; and ( 3 ) the disposition of an interest in the ... Transfer Pricing Debate : The Position Adopted on the Other Side of the Atlan- tic " ( April 1991 ) , 24 Loyola of Los ...
... transfer of property to it ; ( 2 ) the operation of the entity ; and ( 3 ) the disposition of an interest in the ... Transfer Pricing Debate : The Position Adopted on the Other Side of the Atlan- tic " ( April 1991 ) , 24 Loyola of Los ...
Other editions - View all
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