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However, given that the Preamble directly targets treaty-shopping arrangements, it is unclear what the impact of Alta Energy will have on the application of MLI-modified tax treaties go forward. [1] 2018 TCC 152 [2] Article 13(4) of the Luxembourg Treaty. [3] Taking the Minister’s view, drilling or extraction activities would actually have to occur on the property covered by that specific resource license. [4] Alta Energy, at para 68. [5] The general anti-avoidance provision of the Income Tax… [read post]
23 Oct 2012, 9:54 am by Matthew Peters
There is a growing body of Canadian and international jurisprudence on the issue, with the Canadian case of Prevost Car, Inc. v. [read post]
16 Mar 2024, 7:50 am by David Adelstein
Prevost Car, Inc., 660 So. 2d 628 (Fla. 1995), receded from on other grounds by Tiara, 110 So. 3d 399. [read post]
30 Dec 2022, 10:32 am by Michael Oykhman
An example of this might be beating someone severely and leaving them to die in the middle of the road but then a car runs over them ultimately killing them. [read post]