Words and Phrases - "appropriate"

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

Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income

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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 390
Tax Topics - Treaties OECD commentaries applied to Brazil (not an OECD member) 209

Penny v. The Queen, 95 DTC 5083 (FCTD)

appropriation includes de facto taking for which no legal entitlement

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Words and Phrases
appropriate