Canadian Tax Journal, Volume 52, Issues 3-4Canadian Tax Foundation., 2004 - Taxation |
From inside the book
Results 1-3 of 84
Page 986
... shares are grand- fathered . Either the 50 percent rule will apply or half the capital loss will be denied . Under ... shares that were owned on April 26 , 1995 and are subject to a shareholders ' agreement that was in existence on that ...
... shares are grand- fathered . Either the 50 percent rule will apply or half the capital loss will be denied . Under ... shares that were owned on April 26 , 1995 and are subject to a shareholders ' agreement that was in existence on that ...
Page 987
... shares now owned by Mrs. Green can be repurchased by using the $ 1 million of life insurance proceeds and electing the deemed dividend to be paid from the CDA . Alternatively , a $ 1 million capital dividend can be paid to Mrs. Green on ...
... shares now owned by Mrs. Green can be repurchased by using the $ 1 million of life insurance proceeds and electing the deemed dividend to be paid from the CDA . Alternatively , a $ 1 million capital dividend can be paid to Mrs. Green on ...
Page 1225
... shares , for example , is deemed to be " a dividend [ paid ] on a separate class of shares . " The CRA's adminis- trative position appears to be consistent with these provisions . The CRA is willing to treat dividends deemed to have ...
... shares , for example , is deemed to be " a dividend [ paid ] on a separate class of shares . " The CRA's adminis- trative position appears to be consistent with these provisions . The CRA is willing to treat dividends deemed to have ...
Contents
CONTENTS | 713 |
INEQ Studies of Taxes | 741 |
CGE Studies of Taxes | 756 |
Copyright | |
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actionnaires after-tax Alan Macnaughton allocation amount apply arbitrage Canada Canada Revenue Agency Canadian Tax Foundation Canadian Tax Journal canadienne capital gains carrying value cash flows corporate tax cost Court d'une debt deduction of interest disposition distribution dividend refund dividend tax economic effects electronic commerce entity equity être example federal fiscale foreign affiliate Gini coefficient Holdco impact implicit tax income trust income trust structure inequality investment investors IPOS issue legislation Lorenz curve loss montant mutual fund OECD Opco paragraph partnership percent personal tax pre-tax progressivity proposed provincial rachat RDTOH remboursement au titre réputé resident restrictions result revenue royalty trusts segregated funds shareholder shares société straddle transactions studies subsection supra note Tax Conference tax credit tax incidence tax policy tax rate tax system tax treatment taxable taxation taxpayer tion titre de dividendes Toronto transfers