The Resource The Tax Court of Canada strikes offshore bank in Loblaw

The Tax Court of Canada strikes offshore bank in Loblaw

Label
The Tax Court of Canada strikes offshore bank in Loblaw
Title
The Tax Court of Canada strikes offshore bank in Loblaw
Creator
Subject
Language
eng
Summary
Canada statutorily expanded its counterpart to the U.S. attributable subpart F notion in 1994 to include income from an "investment business". In this article, the authors examine that notion and the manner in which the Tax Court of Canada dealt with an exception therefrom for certain foreign bank subsidiaries of Canadian multinationals in its recent Loblaw decision
Citation source
In: Tax notes international. - Falls Church. - Vol. 92 (2018), no. 5 ; p. 513-519
http://library.link/vocab/creatorName
  • Boidman, N
  • Kandev, M.N
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • offshore bank
  • case law
  • Subpart F income
  • GAAR
  • foreign accrual property income
Label
The Tax Court of Canada strikes offshore bank in Loblaw
Instantiates
Publication
Label
The Tax Court of Canada strikes offshore bank in Loblaw
Publication

Library Locations

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      52.3736660 4.9336932
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