[{"pubDate":"Mon, 06 May 2024 22:26:15 +0200","titre":"Stock lending -beneficial ownership and tax avoidance- again!","url":"https://kluwertaxblog.com/2024/02/12/stock-lending-beneficial-ownership-and-tax-avoidance-again/","source":"Kluwer International Tax Blog","id":1306638,"description":"Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158 and, for the first time in Canada in Prévost Car Inc. v R 2008 TCC 231, (affirmed 2009 FCA 57), its meaning and application... Continue"}]