Canadian Tax Journal, Volume 44, Issues 4-6

actions activity allowed amendments amount apply arrangement average basis benefit Canada Canadian Canadian Tax capital changes common considered contribuable corporation cost countries court d'une dans debt decision deduction definition determine direct dividend earned effect establishment être example exemption existing expenses fact federal filed Finance fiscales foreign gains income tax increase individuals interest investment investors issue legislation limited losses means non-resident noted OECD outlined paid paragraph participation particular parties partnership payment pension percent period peut possible premium profit proposed provincial Queen question reasonable received referred regulations reporting resident respect result retirement reviewed rules shareholder shares subsection supra footnote tax rate taxable taxation taxpayer term tion transactions transfer treaty trust United withholding