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Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24 -- summary under Dividend

Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24-- summary under Dividend Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Dividend Discussion (at pp. 9-12) of whether amounts paid as dividends in contravention of the governing corporate law will retain their character as dividends. ...

Smith, "Recent Transactions: Debt", 1993 Conference Report, p. 19:14 -- summary under Paragraph 20(1)(f)

Smith, "Recent Transactions: Debt", 1993 Conference Report, p. 19:14-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) Discussion of whether a debenture that is payable in shares valued at a 5% discount is eligible for the deduction. ...

Lanthier, "Emerging Income Tax Issues: Public Service 2,000, International Finance Companies, and U.S. Limited Liability Companies", 1993 Conference Report, pp. 3:19 - 29 -- summary under Subsection 113(1)

Limited Liability Companies", 1993 Conference Report, pp. 3:19- 29-- summary under Subsection 113(1) Summary Under Tax Topics- Income Tax Act- Section 113- Subsection 113(1) Discussion of U.S. limited liability companies. ...

Lanthier, "Emerging Income Tax Issues: Public Service 2,000, International Finance Companies, and U.S. Limited Liability Companies", 1993 Conference Report, pp. 3:19 - 29 -- summary under Corporation

Limited Liability Companies", 1993 Conference Report, pp. 3:19- 29-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Discussion of U.S. limited liability companies. ...

Smith, "Recent Transactions: Debt", 1993 Conference Report, C. 19 -- summary under Paragraph 20(1)(c)

Smith, "Recent Transactions: Debt", 1993 Conference Report, C. 19-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Discussion of Hollinger LYONS and WIC Transactions; and interest deductibility issues respecting special debenture warrants and debenture instalment receipts. ...

Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16 -- summary under Paragraph 7000(1)(b)

Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16-- summary under Paragraph 7000(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 7000- Subsection 7000(1)- Paragraph 7000(1)(b) Discussion of application of interest accrual rules to arrangements creating unequal interests in personal property. ...

Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3, pp. 3:29-3:31 -- summary under Paragraph 20(1)(c)

Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3, pp. 3:29-3:31-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Discussion of the situation where a Canadian parent borrows funds used to capitalize its U.S. lending subsidiary and the U.S. withholding tax on dividends from the subsidiary eliminates a reasonable expectation of profit. ...

Ewens, "Proposed Amendments Affecting Debt and Equity Reorganizations", 1993 Canadian Petroleum Tax Journal, Vol. 6, No. 1, p. 49 -- summary under Financing Expenditures

Ewens, "Proposed Amendments Affecting Debt and Equity Reorganizations", 1993 Canadian Petroleum Tax Journal, Vol. 6, No. 1, p. 49-- summary under Financing Expenditures Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Pound, "Remedial Tax Planning: How to Fix It When It's Broke", 1993 Conference Report, c. 9, pp. 9:9 - 12 -- summary under Subparagraph 152(4)(a)(ii)

Pound, "Remedial Tax Planning: How to Fix It When It's Broke", 1993 Conference Report, c. 9, pp. 9:9- 12-- summary under Subparagraph 152(4)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(ii) Includes a reference to the decision of the Quebec Court of Appeal in Banque Nationale du Canada v. ...

Matthew Warren, Eileen Scott, Alan Fischl, Sergio Lugo Dimas, "U.S. Foreign Tax Credibility of the Mexican Cash Deposits Tax", Journal of International Taxation, October 2013, p. 37 -- summary under Non-Business-Income Tax

Limited Liability Companies", 1993 Conference Report, pp. 3:19- 29: discussion of U.S. limited liability companies. Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3. ... Commissioner ", Tax Management International Journal, October 8, 1993, p. 539: Discussion of Brazilian interest withholding tax of 25% in respect of which borrowers taking out loans duly registered with the Brazilian Central Bank could receive a pecuniary benefit equal to 85% of the tax paid on the interest. ...

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