Submitted by narmstrong on Thu, 10/25/2018 - 01:36
effective date references the taxation year of the SBD corp rather than the associated corp
At all relevant times, a Canadian-controlled private corporation (ACo) with a calendar taxation year and having income of $500,000 per year of...
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Principal Issues: We have been asked to provide guidance on how the new passive income reduction will apply to the reduction of the business limit for associated corporations with differing taxation years.
Position: The passive income reduction will apply for taxation years that begin after 2018. A corporation’s adjusted aggregate investment income is the total of all amounts each of which is the adjusted aggregate investment income of the corporation or any corporation with which it is associated at any time in a particular taxation year for each taxation year of the corporation, or associated corporation that ended in the preceding calendar year.
248(1)(d)(i) of the definition of "mineral resource"
Principal Issues: Whether the limestone deposits described below meet the definition of "mineral resource" in subparagraph 248(1)(d)(i) (Minister of Natural Resources Certification is required).
Position: The limestone deposits described below do not meet the requirements of the definition of "mineral resource" in subparagraph 248(1)(d)(i), such that no certification from the Minister of Natural Resources has been provided.
Reasons: The taxpayer is extracting rock, rather than a mineral, from the deposits.
Principal Issues: Whether an amount paid by a former employer as compensation for the loss in the value of an employee’s house is an eligible housing loss for the purposes of subsection 6(20) of the Act.
Position: The amount paid for the housing loss must be in respect of an eligible relocation.
Principal Issues: Whether an amount paid by a former employer as compensation for the loss in the value of an employee’s house is an eligible housing loss for the purposes of subsection 6(20) of the Act.
Position: The amount paid for the housing loss must be in respect of an eligible relocation.
