Words and Phrases - "means"
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...
Words and Phrasesmeans
|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|