The Resource Canada deems an Austrian private foundation a corporation rather than a trust

Canada deems an Austrian private foundation a corporation rather than a trust

Label
Canada deems an Austrian private foundation a corporation rather than a trust
Title
Canada deems an Austrian private foundation a corporation rather than a trust
Creator
Subject
Language
eng
Summary
In its recent decision, Sommerer v. The Queen (2012 FCA 207), the Canadian Federal Court of Appeal in a strong obiter dictum found an Austrian private foundation (Privatstiftung) to be a corporation, rather than a trust for Canadian income tax purposes. Since Austrian private foundations are widely used by non-residents of Austria for the same economic purposes as common law trusts, this determination is especially important in an international tax planning context. This article considers the essential elements of a Canadian trust, the Austrian private foundation, and the court's assessment
Citation source
In: Tax planning international : European tax service. - London. - Vol. 15 (2013),
http://library.link/vocab/creatorName
  • Schmidt, N.J.R.M
  • Binder, K
Geographic coverage
  • North America
  • Europe
  • European Union
Language note
English
http://library.link/vocab/subjectName
  • private foundation
  • trust
  • entity classification
  • case law
  • international tax planning
Label
Canada deems an Austrian private foundation a corporation rather than a trust
Instantiates
Publication
Label
Canada deems an Austrian private foundation a corporation rather than a trust
Publication

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