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The Case for Reverse Depreciation of Reclamation Costs JOSEPH FRANKOVIC
Comments on International Taxation in the Age of Electronic
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allowed amended américain amount appeal apply approach argument assessment assignment Bank basis beneficiary benefit Canada Canadian tax capital consideration considered contribution corporation Court decision deduction deemed definition depreciation determining discussed distribution dividend earned economic effect electronic commerce employee entity être example exempt existing expenses fact federal fiscal foreign future imposed income tax increase individual interest investment issue jurisdiction l'employé l'impôt liability limitation minister non-resident obligation OECD option paid paragraph particular particulier partnership payment percent period person peut position present principles profits proposed provisions question reason reassessment received reclamation costs referred resident respect result revenu reverse rules shares subsection supra note tax purposes taxable taxation taxpayer teams tion transactions transfer treatment treaty trust United