Words and Phrases - "liable to tax"
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...
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Tax Topics - Treaties - Income Tax Conventions | 83 |