The Resource The taxation of corporate reorganizations : income tax implications of utulizing bare trusts

The taxation of corporate reorganizations : income tax implications of utulizing bare trusts

Label
The taxation of corporate reorganizations : income tax implications of utulizing bare trusts
Title
The taxation of corporate reorganizations : income tax implications of utulizing bare trusts
Creator
Subject
Summary
At the 1988 round table, Revenue Canada stated that where a bare trust exists under common law, subsections 104 (1), 104(2), and 75(2) of the Income Tax Act will apply. If correct, this would visit unintended and undesirable tax consequences on many common corporate reorganizations and commercial transactions. In this article the authors believe that bare trusts involve a mixed agency-trust relationship in which agency is usually pre-dominant. As such, bare trusts should generally be ignored for purposes of the Income Tax Act
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 37 (1989),
http://library.link/vocab/creatorName
  • Ewens, D.S
  • Wertschek, R
  • Wilson, J.R
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • trust
  • agency
  • reorganization
Label
The taxation of corporate reorganizations : income tax implications of utulizing bare trusts
Instantiates
Publication
Label
The taxation of corporate reorganizations : income tax implications of utulizing bare trusts
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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