Canadian Tax Journal, Volume 51, Issues 3-4Canadian Tax Foundation., 2003 - Taxation |
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Results 1-3 of 53
Page 1082
... international tax arbitrage in the context of foreign direct investment . KEYWORDS : INTERNATIONAL TAX COMPETITION INTERNATIONAL TAX ARBITRAGE □ CORPORATE TAX BASE COORDINATION FOREIGN DIRECT INVESTMENT FOREIGN PORTFOLIO INVESTMENT ...
... international tax arbitrage in the context of foreign direct investment . KEYWORDS : INTERNATIONAL TAX COMPETITION INTERNATIONAL TAX ARBITRAGE □ CORPORATE TAX BASE COORDINATION FOREIGN DIRECT INVESTMENT FOREIGN PORTFOLIO INVESTMENT ...
Page 1106
... international tax competition and international tax arbitrage identified above . As framed in certain of the literature , arguments regarding the policy stakes presented by international tax competition and international tax arbitrage ...
... international tax competition and international tax arbitrage identified above . As framed in certain of the literature , arguments regarding the policy stakes presented by international tax competition and international tax arbitrage ...
Page 1113
Foreign law is not accepted as determinative of domestic tax consequences gener- ally . This determinative status is limited to those circumstances in which ... international tax arbitrage can have the CORPORATE INCOME TAX COORDINATION 1113.
Foreign law is not accepted as determinative of domestic tax consequences gener- ally . This determinative status is limited to those circumstances in which ... international tax arbitrage can have the CORPORATE INCOME TAX COORDINATION 1113.
Contents
corporate status in the source country for all resident entities that are used to structure | 1083 |
Defining a Common Policy Problem | 1104 |
Corporate Income Tax Coordination as a Common Response | 1121 |
Copyright | |
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accounting actions amount apply arm's-length assets autre basis bénéficiaires beneficiaries benefit bien Canada Canadian Tax Foundation canadienne capital gain cash CCQ article CCRA CCRA's common law compensation context corporate residence cost Court Couzin d'une deduction deferral discount discretionary discretionary trust discrétionnaire disposition dividend droit earnings economic effect employee stock options employment insurance estate freeze être exercise expenses family businesses FAPI federal fiduciaire fiducie fiscal foreign direct investment foreign tax Ibid income tax independent contractors interest international tax arbitrage international tax competition issue jurisdiction l'article lease OECD Opco paid paragraph payment percent person peut pouvoir provides purposes Quebec réputé revenue rules shareholders shares société subsection supra note tax competition Tax Conference tax credit tax policy tax rate tax system tax treaties taxable taxation taxpayer tion Toronto transactions transfer trust trust instrument vicarious liability