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Application of the Charter to Civil Penalties in the Income Tax Act COLIN CAMPBELL
Policy and Practice JOEL NITIKMAN
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accounting actions activities allow amount appeal apply approach assessment assets authorities base basis benefit bien Canada Canadian Tax capital carried CCRA changes comparables conjoint considered contributions convention corporation cost countries Court debt decision deduction determine discussion dividends economic effect establishment example exemption existing expenditures fact federal fiducie Finance fiscal foreign affiliate Foundation gains important income tax increased individual interest interpretation investment issue Journal limited loss meaning municipal OECD operating paid paragraph partnership percent period permanent person position profit proposed provincial question reasonable received referred reform Report residence respect result revenu rules shares société spouse subsection suggested supra note tax treaties taxable taxation taxpayer Toronto transfer treatment trust United