Canadian Tax Journal, Volume 44, Issues 4-6Canadian Tax Foundation., 1996 - Taxation |
From inside the book
Results 1-3 of 77
Page 1147
... respect of royalties on the basis of the practical problems of allocating ownership of an intangible asset to a particular division of an enterprise.73 In addition , the 1994 OECD commentary update explains its disallowance of notional ...
... respect of royalties on the basis of the practical problems of allocating ownership of an intangible asset to a particular division of an enterprise.73 In addition , the 1994 OECD commentary update explains its disallowance of notional ...
Page 1219
... respect of which a promoter is re- quired by section 237.1 to register can there exist , in the writer's view , a " tax shelter investment " for the purpose of the reference to a " tax shelter " in paragraph ( a ) of the above ...
... respect of which a promoter is re- quired by section 237.1 to register can there exist , in the writer's view , a " tax shelter investment " for the purpose of the reference to a " tax shelter " in paragraph ( a ) of the above ...
Page 1665
... respect to the appropri- ate treatment of payments for the use of software are reviewed . Revenue Canada's Response Whether the outright sale of the software will be treated as an income or capital receipt is a question of fact . If ...
... respect to the appropri- ate treatment of payments for the use of software are reviewed . Revenue Canada's Response Whether the outright sale of the software will be treated as an income or capital receipt is a question of fact . If ...
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activity amendments apply assets autres bénéficiaire beneficiary benefit biens British Columbia Canadian Tax Foundation Canderel capital gains common shares contribuable corporation cost critère d'assurance vie d'une debt décès deduction direct tax effect entreprise été exemption expectation of profit expenses federal fiducie filed Finance foreign property guideline amount Holdco income tax interest investment investors issue l'entreprise l'impôt legislation limited partnership losses marginal tax rate Moldowan montant non-resident OECD Ontario Opco paragraph payer payment payroll taxes pension percent permanent establishment pertes peuvent premium provincial qu'il Queen raisonnable de profit reasonable expectation reporting resident result retirement Revenue Canada reviewed RRSP rules shareholder société Stéphane subsection supra footnote Tax Conference tax rate tax shelter tax treaty taxable taxation taxpayer tion Tonn Toronto transactions trust underground economy valeur de rachat Zealand