Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 83
Page 432
... Interest and Guarantee Fees Of relevance in structuring the financing obligations of shareholders under a shareholders ' agreement is the deductibility by shareholders of interest on sums borrowed by the shareholders and the treatment ...
... Interest and Guarantee Fees Of relevance in structuring the financing obligations of shareholders under a shareholders ' agreement is the deductibility by shareholders of interest on sums borrowed by the shareholders and the treatment ...
Page 433
... interest ( or at no interest ) , to be used in its operation to produce income from business or property which will be subject to Part I tax in Canada , ( b ) the corporation has made every effort to borrow the necessary funds through ...
... interest ( or at no interest ) , to be used in its operation to produce income from business or property which will be subject to Part I tax in Canada , ( b ) the corporation has made every effort to borrow the necessary funds through ...
Page 725
... interest . It was an adventitious benefit unconnected with its larger ambitions . Their Lordships think that the justice of the case was more than adequately met by the commis- sioner treating it as a subsidiary purpose and allowing a ...
... interest . It was an adventitious benefit unconnected with its larger ambitions . Their Lordships think that the justice of the case was more than adequately met by the commis- sioner treating it as a subsidiary purpose and allowing a ...
Other editions - View all
Common terms and phrases
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