Words and Phrases - "revert"
9 March 2007 External T.I. 2006-0218501E5 F - Application de 75(2) lors d'une émission d'actions
s. 75(2) inapplicable to a corporation issuing shares to a trust of which it may become a beneficiary because it did not own the shares before their issuance
Would s. 75(2) apply to dividends on shares of a corporation that are subscribed for by a trust where the corporation subsequently could become a...
Words and Phrases
revertCanada v. Sommerer, 2012 DTC 5126 [at 7219], 2012 FCA 207
Austrian foundation likely not a trust
Before allowing the taxpayer's appeal from an assessment made on the basis that s. 75(2) applied to attribute a capital gain realized by an...
Words and Phrases
revertLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 248 - Subsection 248(5) | 84 | |
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | does not apply to FMV purchases | 236 |
Tax Topics - Treaties - Income Tax Conventions | treaty applies to economic double taxation | 356 |
Tax Topics - Treaties - Income Tax Conventions - Article 13 | attributed gain not included | 415 |