Canadian Tax Journal, Volume 49, Issues 1-3Canadian Tax Foundation., 2001 - Electronic journals |
From inside the book
Results 1-3 of 79
Page 20
... transactions , arranged in such a way that the particular provisions of the Act are met , on the basis that it would be inequitable to those taxpayers who have not chosen to structure their transactions that way .... The courts ' role ...
... transactions , arranged in such a way that the particular provisions of the Act are met , on the basis that it would be inequitable to those taxpayers who have not chosen to structure their transactions that way .... The courts ' role ...
Page 30
... transactions with real economic substance , not to transactions intended to exploit , misuse , or frustrate the Act to avoid tax . " 108 The general anti - avoidance rule does not enact an economic substance over legal form doctrine ...
... transactions with real economic substance , not to transactions intended to exploit , misuse , or frustrate the Act to avoid tax . " 108 The general anti - avoidance rule does not enact an economic substance over legal form doctrine ...
Page 717
... transactions were undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit and could not be characterized as " avoidance transactions . " Judge Bonner reached a similar conclusion in Canadian Pacific ...
... transactions were undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit and could not be characterized as " avoidance transactions . " Judge Bonner reached a similar conclusion in Canadian Pacific ...
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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