Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 88
Page 396
... proposed section 134.1 election is available only to a corporation that was an NRO in one taxation year but not an NRO in the next . Assume , for example , that an NRO lost its status owing to an amalgamation with another Canadian ...
... proposed section 134.1 election is available only to a corporation that was an NRO in one taxation year but not an NRO in the next . Assume , for example , that an NRO lost its status owing to an amalgamation with another Canadian ...
Page 401
... proposed amendments come as no great surprise , they will have major implications for foreign entities with investments in Canada . The proposed thin capitalization rules , along with the repeal of the NRO provisions , affect how many ...
... proposed amendments come as no great surprise , they will have major implications for foreign entities with investments in Canada . The proposed thin capitalization rules , along with the repeal of the NRO provisions , affect how many ...
Page 501
... proposed regula- tions ( " the new proposed regulations " ) governing the qualification for treaty benefits of US - source payments by " reverse hybrid " US entities ( USRHES ) to non - US ( " foreign " ) interest holders ( FIHS ) in ...
... proposed regula- tions ( " the new proposed regulations " ) governing the qualification for treaty benefits of US - source payments by " reverse hybrid " US entities ( USRHES ) to non - US ( " foreign " ) interest holders ( FIHS ) in ...
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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