The Resource Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation

Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation

Label
Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation
Title
Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation
Creator
Subject
Language
eng
Summary
In Sommerer v the Queen, Canada's Federal Court of Appeal rendered a welcome decision for Canadian tax and trust practitioners, while providing relevant and insightful comments on whether a private foundation established under Austrian civil law constitutes an arrangement similar to a trust for common law purposes. This articles discusses the decision and how the Federal Court of Appeal's comments could provide a useful point of departure for practitioners in common law jurisdictions tasked with classifying European private foundations for the purposes of their own domestic law
Citation source
In: Trusts & trustees. - Oxford. - Vol. 20 (2014),
http://library.link/vocab/creatorName
  • Rochwerg, M.J
  • Sharma, R
Language note
English
http://library.link/vocab/subjectName
  • private foundation
  • trust
  • entity classification
  • tax treaty
  • capital gains
  • case law
Label
Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation
Instantiates
Publication
Label
Sommerer v The Queen - the Canadian common law and tax treatment of an Austrian private foundation
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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