Words and Phrases - "means"

82
43
74
50
35
31
17
13
70
2
2
30
51
25
37
79
2
73
85
44
14
8
20
2
1

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

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