Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 81
Page 6
... taxpayer is entitled to arrange his affairs to mini- mize tax is based on the strict approach to the interpretation of taxation statutes . According to this approach , unless a taxpayer's situation is literally within the words of the ...
... taxpayer is entitled to arrange his affairs to mini- mize tax is based on the strict approach to the interpretation of taxation statutes . According to this approach , unless a taxpayer's situation is literally within the words of the ...
Page 16
of their transactions . The court could more easily have found that the taxpayer had the right to arrange his affairs to minimize tax and that the taxpayer must be assessed on the basis of what he did - sold shares - not what he might ...
of their transactions . The court could more easily have found that the taxpayer had the right to arrange his affairs to minimize tax and that the taxpayer must be assessed on the basis of what he did - sold shares - not what he might ...
Page 20
... taxpayer's bona fide legal relationships . To the contrary , we have held that , absent a specific provision of the Act to the contrary or a finding that they are a sham , the taxpayer's legal relationships must be respected in tax ...
... taxpayer's bona fide legal relationships . To the contrary , we have held that , absent a specific provision of the Act to the contrary or a finding that they are a sham , the taxpayer's legal relationships must be respected in tax ...
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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