Canadian Tax Journal, Volume 43, Issues 1-4

activities addition administrative affiliate agreement allow amendments amount appears apply assessment assets basis beneficiaries benefit biens borrowed Canadian Tax capital carried China Conference considered contribuable corporation cost court d'une dans debt deduction deemed determine discussion disposition dividends documents effect election été être example exempt expenditures fair federal fiducie Finance fiscales foreign gain income tax increase interest International investment issue legislation limited loan loss market value million non-resident obligation paid paragraph particular parties partnership payment pension percent person proposed provides provincial question reasonable received referred regulations Report resident respect result Revenue Canada rules shareholder shares société subsection supra footnote taxable taxation taxpayer tion Toronto transactions transfer treaty trust United withholding