Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 83
Page 303
... considered to be a disposition of property , the cost of which to the grantor is nil : see subsection 49 ( 1 ) . In the United States , the grant of virtually all options is considered an " open transaction , " and no tax consequences ...
... considered to be a disposition of property , the cost of which to the grantor is nil : see subsection 49 ( 1 ) . In the United States , the grant of virtually all options is considered an " open transaction , " and no tax consequences ...
Page 310
... considered a capital gain whereas , on the basis of the majority judgment , the $ 10 realized by the second would be ordinary income because it is compensation for services . For a critique of Harlan J's reasoning , see infra note 142 ...
... considered a capital gain whereas , on the basis of the majority judgment , the $ 10 realized by the second would be ordinary income because it is compensation for services . For a critique of Harlan J's reasoning , see infra note 142 ...
Page 503
... considered fiscally transparent by that jurisdiction . If the FIH is considered fiscally transparent by that jurisdiction , however , then a literal reading of the new proposed regulations suggests that treaty ben- efits will not be ...
... considered fiscally transparent by that jurisdiction . If the FIH is considered fiscally transparent by that jurisdiction , however , then a literal reading of the new proposed regulations suggests that treaty ben- efits will not be ...
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actions agreement amount apply assets benefit Bob and Margaret budget C.D. Howe Institute Canada Canadian Tax Foundation canadienne capital dividend CCED CCRA charity compte conjoint context contributions convention des actionnaires corporation Court d'actions d'une décès deduction deemed discussion draft disposition dividendes en capital droit Duha Duke of Westminster earnings economic employee stock options entreprise equity estate freeze été être fair market value Finance fiscal flat tax gains en capital Ibid incentives income tax input tax investment issue juste valeur marchande l'article l'impôt limits montant OECD paragraph partie payment percent permanent establishment person pertes peut preferred shares produit profit purpose Quebec rachat réduit règles réputé revenue Roth IRAS RRSPs rules shareholders société statutory subsection supra note taux tax avoidance tax credit tax rates tax treaties tax treatment tax-deferred tax-prepaid taxable taxation taxpayer tion Toronto TPSP transactions United vertu