Canadian Tax Journal, Volume 44

acquired actions activities allowance amalgamation amendments amount Appeal apply basis beneficiary benefits bien Canadian Canadian Tax capital capital cost charges circumstances concluded Conference consequences considered contribuable convention corporation cost Court d'une debt decision deduction deemed definition depreciable determine disposition distribution dividend effect employee être example exemption expenses fact fair Federal fiducie Finance fiscal foreign funds gain held Income Tax increase interest interpretation inventory investment issue legislation limited loss meaning notes OECD paid paragraph parent particular partie partnership payment payroll percent person planning principal provisions Queen question reasonable received referred relevant Report resident respect result Revenue Canada rules shares situation specific subsection subsidiary supra footnote taxable taxation taxpayer term tion transactions transfer treaty trust United winding