The Resource Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act

Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act

Label
Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act
Title
Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act
Creator
Subject
Language
eng
Summary
The purpose of this article is to posit an approach to the classification of foreign business entities based on a determination of whether the entity is a "corporation" / "société" for Canadian tax purposes. The authors begin by reviewing the background to and setting out their views on the relevance of foreign entity classification. They then focus on the notion of corporation / société in Canadian tax law and expound their views on the proper common meaning of these terms in the English and French versions of the relevant statutes. Finally, building on this analysis, the authors propose an approach to foreign entity classification that they believe to be fully consistent with the scheme and purpose of Canadian tax law and with an often-overlooked Tax Appeal Board decision on point
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 57 (2009),
http://library.link/vocab/creatorName
  • Boidman, N
  • Kandev, M.N
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • entity classification
  • partnership
  • hybrid entity
  • case law
Label
Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act
Instantiates
Publication
Label
Foreign entity classification and the meaning of "corporation" / "société" in the Income Tax Act
Publication

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