Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 78
Page 30
... result in a misuse of the provisions of the Act or an abuse having regard to the provisions of the Act read as a whole . If the Supreme Court does not recognize the fundamental inconsistency between the Duke of Westminster principle ...
... result in a misuse of the provisions of the Act or an abuse having regard to the provisions of the Act read as a whole . If the Supreme Court does not recognize the fundamental inconsistency between the Duke of Westminster principle ...
Page 421
... result in a deemed dividend from the corporation to be acquired to the vendor's holding company , which would otherwise be deduct- ible . If the strategy were successful , the vendor would avoid tax on the capital gain that would ...
... result in a deemed dividend from the corporation to be acquired to the vendor's holding company , which would otherwise be deduct- ible . If the strategy were successful , the vendor would avoid tax on the capital gain that would ...
Page 794
result in a tax - free payment to the corporation and a credit to the corporation's capital dividend account . In short , in the investment holding company context , the emphasis will be on recovering RDTOH and , to the extent possible ...
result in a tax - free payment to the corporation and a credit to the corporation's capital dividend account . In short , in the investment holding company context , the emphasis will be on recovering RDTOH and , to the extent possible ...
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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