Words and Phrases - "attributable"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 24
Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income

The Crown brought a motion under Rule 58(1) for determination of questions of law respecting the application of Art. XXII(2) of the Canada-Brazil...

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Words and Phrases
appropriate attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) foreign source interest reduced by related expenses 412
Tax Topics - Treaties - Income Tax Conventions OECD commentaries applied to Brazil (not an OECD member) 231