TAXATION AND SITUS: COMPANY SHARES
AbstractIn this article the author discusses the issue of taxing intangible things, in particular the assignment of a situs for taxation purposes. In discussing one intangible situs, company shares, the article outlines the constitutionality of provincial taxing power in relation to the taxation of company shares. After briefly outlining the “one local situation” rule, as outlined in recent jurisprudence, the author argues that taxation of an intangible situs may be within provincial jurisdiction in some cases. Lastly, the potential of jurisdictional conflicts with share certificates was outlined by the author as the question which must be answered in future discussions and examinations.
Keywords:Company Law, Succession Duty
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