Canadian Tax Journal, Volume 49, Issues 1-3

actionnaires actions activities agreement allow amount apply approach assets base basis benefit Canada Canadian Canadian Tax capital capital gains cent changes computing considered contributions convention corporation cost Court d'une dans deduction deemed determined discussion disposition dividend draft earnings economic effect employee establishment être example exemption exercise existing expenses fair Finance fiscal foreign freeze fund gains granted income tax increase individual interest interpretation investment issue l'impôt limits loss meaning method OECD option paid paragraph partie payment percent period person plans production profit proposed purchase Quebec question received referred Report respect result rules savings shareholders shares société stock options subsection supra note tax rates taxable taxation taxpayer tion transactions transfer treatment United