The Resource Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident

Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident

Label
Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident
Title
Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident
Creator
Subject
Summary
Article about an important case before the Canadian Tax Court (Equilease Corporation). The Court applied the general anti- avoidance rule ("GAAR") in a cross-border context, in particular the recharacterisation of a tax exempt share sale into taxable dividends. This presents significant questions regarding the interaction of the GAAR with Canada's international tax treaties
Citation source
In: Journal of international taxation. - New York. - Vol. 8 (1997),
http://library.link/vocab/creatorName
Kingissepp, A.H
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • anti-avoidance
  • case law
  • tax treaty
Label
Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident
Instantiates
Publication
Label
Canadian Tax Court holds general anti-avoidance rule applies to deny tax treaty benefits to US resident
Publication

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