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Conversion of income into capital gains
Canada Trustco Mathew and Their Aftermath
Where are we now?
Notice of appeal
The Operation of the GAAR
Towards a Textual Contextual and Purposive Interpretation
GST and the GAAR
The GA AR and Treaties
The GA AR and the Income Tax Regulations
The GA AR in Other Countries
APPENDIX A Information Circulars
APPENDIX B GAAR Case Law
abuse addition allowance amount analysis anti-avoidance rule apply approach arm's length arrangement assessment avoidance transaction basis bona fide borrowed business purpose Canada Trustco Canadian capital carried claimed concluded considered context corporation cost Court of Appeal Court of Canada decision deduction Department determine dividend effect evidence facts Federal Court Finance GAAR held Holdings Income Tax intended interest interpretation investment involved issue judge legislation Limited loan loss meaning Minister misuse notice object obtain OSFC paid paragraph particular parties partnership payment permit person planning position primarily proposed provisions purchase Queen question reasonable reassessment received reduce referred regard relevant relied respect result rule scheme section 245 series of transactions shares specific spirit statutory statutory interpretation step subsection supra note Supreme Court tax benefit Tax Court taxable taxation taxpayer tion transfer treaty whole