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Results 251 - 254 of 254 for considered
Article Summary
Kevyn Nightingale, "American Professionals in Canada", Canadian Tax Journal, (2017) 65:4, 893-937 -- summary under Subsection 126(1)
The corporate tax is eligible for credit, since it is considered to have been paid by the individual. ...
Article Summary
Gwendolyn Watson, "The Foreign Affiliate Surplus Reclassification Rule", Canadian Tax Journal (Canadian Tax Foundation) (2019) 67:4, 1233-66 -- summary under Subsection 5907(2.02)
These cases considered the issue in the context of property that ceased to exist under the doctrine of merger in connection with the transfer. ...
Article Summary
Nelson Whitmore, Owen Strychun, "Canadian Inbound Investment After the MLI", Canadian Tax Journal, (2019) 67:3, 831-80 -- summary under Article 7(1)
According to the commentary, even though state R's extensive treaty network was considered by the fund in determining where RCO should be formed, it would not be reasonable to deny treaty benefits to RCO in this circumstance since the company was established to deliver on the commercial mandate of the fund to buy and sell real estate investments. ...
Article Summary
Lee A. Sheppard, "The Brave New World of the Dependent Agent PE", Tax Notes International, Vol. 71, No. 1, 1 July 2013, p. 10 -- summary under Article 5
Roche considered whether the subsidiary did the parent's business in Spain. ...