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- Title
THE DEDUCTIBILITY OF ADVISORY FEES INCURRED TO REDUCE WITHHOLDING TAXES ON INBOUND PAYMENTS.
- Authors
Palmer, Ashley; Walker, Ryan
- Abstract
The article discusses the court case, Potash Corp. of Saskatchewan Inc. v. The Queen, which raised the issue of the deductibility of legal and accounting fees incurred by Canadian corporation to implement reorganization for the purpose of reducing foreign withholding taxes repatriated to the Canadian corporation by a subsidiary. The court ruled that these fees were eligible capital expenditures, thus deductible under paragraph 20 of the Canadian Tax Act.
- Subjects
ACTIONS &; defenses (Law); POTASH Corp. of Saskatchewan Inc.; CANADIAN corporations; FOREIGN tax credit; CAPITAL investments
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2011, Vol 59, Issue 3, p554
- ISSN
0008-5111
- Publication type
Article