Search - стрим ешмек шешу

Demarcation between s. 106(2) and 106(3) [S]ubsection l06(2) … is intended to apply to situations in which an income interest is disposed of to and acquired by a third party, while subsection 106(3) deals with the situation in which an income interest is disposed of to the trust itself and thereby eliminated. ...

Desirability or undesirability of elevating surplus from lower-tier affiliates rather than making It may be beneficial for the payer of an interaffiliate dividend, who has sufficient tax-free surplus, to pay a dividend to a higher-tier foreign affiliate from such tax-free surplus, so as to elevate tax-free surplus up the foreign affiliate chain, thereby making such surplus more readily available to shelter the payment of any subsequent dividends to the CRIC – and also safeguarding that tax-free surplus from erosion by any subsequently-incurred losses of the payer affiliate. ...

. … we believe that a reasonable basis exists where there is some authority for the filing position taken, and no obvious authority to the contrary. ...

The transfer of shares from treasury to the 7(2) Trust could be completed after a corporate freeze transaction or during the start up phase of operations, so that the shares acquired by the 7(2) Trust (through a fair market value share subscription, or through a contribution of the shares by the employer corporation for no consideration) would have a nominal value – so that the employment benefit to the employees also could be nominal. ...

This … may not have arisen if, for example, Foreign Spinco held the DC shares through a single purpose foreign holding company. ...