Report of Proceedings of the Tax Conference Convened by the Canadian Tax Foundation

agreement amended amount apply arbitration arm's length assets beneficiary British Columbia business in Canada Canada Revenue Agency Canada Trustco Canadian dollars Canadian Tax Foundation Canco capital gains carrying on business competent authorities considered context Court of Appeal CRA's debt deduction deemed definition determining eligible dividend employee equity example exempt federal Finco fund GAAR Ibid Imperial Oil income tax Income Tax Act income trust interest interpretation investment issue legislation liability limited liability company litigation loan loss OECD Opco paid paragraph parties partners partnership payment percent permanent establishment person privilege proposed province Quebec regulations relevant resident in Canada respect result retroactive Revenue rules section 94 shareholder shares solicitor-client privilege specific subparagraph subsidiary supra note Supreme Court tax avoidance tax benefit Tax Court tax purposes tax treaty taxable taxation taxpayer tion transaction transfer United Univar USco withholding tax