The Resource Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act

Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act

Label
Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act
Title
Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act
Creator
Subject
Language
eng
Summary
The article provides a critical review of the proposed amendments to the rules in section 94 of the Canadian Income Tax Act, which are considered on the basis of domestic and international legal and tax policy principles, and assesses the structural approach adopted in the legislation on the basis of a comparative analysis of the provisions with the US grantor trust rules in section 679 of the Internal Revenue Code and the Treasury regulations thereunder. Suggests that two fundamental aspects of the approach adopted in amending the provisions governing the taxation of non-resident trusts are inappropriate abd should be reconsidered
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 52 (2004),
http://library.link/vocab/creatorName
Roth, E.S
Geographic coverage
North America
Language note
  • English
  • French
http://library.link/vocab/subjectName
  • trust
  • income tax law
  • tax policy
  • tax treaty
Label
Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act
Instantiates
Publication
Label
Canadian taxation of non-resident trusts : a critical review of section 94 of the Income Tax Act
Publication

Library Locations

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      52.37366609999999 4.9336932
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