Philippe Montillaud, Grant J. Russell, "Foreign Accrual Tax and Flow-through Entities", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1280

No relief where PPOP is the hybrid (p. 1281)

Subsection 91(4.5) does not provide relief, however, where the PPOP itself is the hybrid entity. For...

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Application of s. 93(2.01) stop-loss rule to DLAD capital loss (p. 1282)

Regulation 5907(5) requires that capital gains and losses for surplus...

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Application of s. 93(2.01) stop-loss rule to DLAD capital loss (p. 1282)

Regulation 5907(5) requires that capital gains and losses for surplus...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.