Words and Phrases - "liable to tax"
Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49, [2021] 3 S.C.R. 590
a company resident under Luxembourg domestic law (its legal seat was there), and that was “liable to be liable to tax,” was resident there for Treaty purposes even though a conduit
In considering whether there had been a treaty-shopping abuse of the Canada-Luxembourg Treaty by virtue of the taxpayer, which had its legal seat...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse | 660 |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | utilization of the business property exemption by a Luxembourg conduit accorded with the bargain negotiated by Canada, which was to encourage investment by such investors | 605 |
| Tax Topics - Treaties - Income Tax Conventions | subsequent OECD Treaty commentary not followed | 198 |
| Tax Topics - Statutory Interpretation - Treaties | additional consideration in Treaty context of giving effect to the contractual bargain | 237 |
19 August 2010 External T.I. 2009-0344111E5 F - Résidence Société Capital-Risque - Conv Can-France
French venture capital corporation is resident in France (“liable to tax”) notwithstanding that it has elected to be exempt on its portfolio gains
In finding that a French venture capital corporation ("VCC"), that was resident in France for French taxation purposes by virtue of its domicile...
Words and Phrases
liable to taxCrown Forest Industries Ltd. v. Canada, 95 DTC 5389, [1995] 2 S.C.R. 802, [1995] 2 CTC 64
Some of the income derived from a corporation incorporated in the Bahamas was effectively connected with the conduct by it of a business in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions | 83 |