Words and Phrases - "means"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
74
s
85
t
44
u
14
v
8
w
20
y
2
“
1

Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 4
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...

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Words and Phrases
means
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