Words and Phrases - "appropriate"

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43
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13
71
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30
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Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3

Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income

The Crown brought a motion under Rule 58(1) for determination of questions of law respecting the application of Art. XXII(2) of the Canada-Brazil...

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Words and Phrases
appropriate attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) foreign source interest reduced by related expenses 412
Tax Topics - Treaties - Income Tax Conventions OECD commentaries applied to Brazil (not an OECD member) 231

Penny v. The Queen, 95 DTC 5083, [1995] 1 CTC 114 (FCTD)

appropriation includes de facto taking for which no legal entitlement

An account receivable owing to a private corporation controlled by the taxpayer was found to have been appropriated by him given the receipt (and...

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Words and Phrases
appropriate