Search - отримати ешмек шешу

IT-305R3 "Establishment of Testamentary Spouse Trust"-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt In interpreting the requirement that the spouse must be entitled to receive all the income of a spouse trust that arises before the spouse's death, RC applies the doctrine of constructive receipt. ...

IT-436R "Reserves- Where Promissory Notes are Included in Disposal Proceeds"-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note has been accepted as absolute payment for the disposition of a property, no amount is due in respect of the disposition, because the debt is considered to have been paid or satisfied by the receipt of the promissory note. ...

IT-243R4, para 5-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt mere crediting of account "A corporation is not considered to have paid a dividend when it merely credits a shareholder's account, unless the shareholder is able to withdraw the money credited at any time. ...

IT-196R2 "Payments by Employer to Employee"-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxable payment is included in computing the employee's income on the earliest taxation year in which he receives it, absolute enjoyment or use vests in him, or it is paid or transferred pursuant to his direction. ...

.-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

.- Q.29-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Constructive receipt by an employee benefit plan beneficiary occurs when an amount is made available to him without being subject to any restrictions concerning its use. ...

.- Q.13-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Under an unfunded deferred compensation plan, constructive receipt is considered to occur in situations where an amount is credited to an employee's account, set apart for the employee, or is otherwise available to the employee without being subject to any restriction concerning its use. ...

3 July 1991 Memorandum (Tax Window, No. 5, p. 22, ¶1335)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A journal entry recording a transfer of an amount from a salary payable account to a loan from shareholder account does not by itself constitute payment of the salary. ...

Round Table, Q.15-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt There is no repayment for the purposes of s. 20(1)(hh) when shares are converted to a debt security and the parties are in essentially the same situation before and after the conversion. ...

Toronto Centre Canada Revenue Agency & Professionals Group Newsletter, Vol. 13-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Issue 4, December 2014 …Pilot project: Pre-ruling consultations Framework The Income Tax Rulings Directorate (ITRD) is offering…[t]he pre-ruling consultation [which] will allow the Applicant to discuss with ITRD professionals (the ITRD Representatives) any unique, new technical issue that is critical to the structuring of seriously proposed transactions in advance of submitting a ruling request. ... ITRD …Subject to operational requirements, ITRD will schedule a teleconference within 3 weeks from the date on which a complete Application is received. … Agreement to participate in a pre-ruling consultation does not constitute the commencement of the ruling process and it will not give priority if an advance income tax ruling request is ultimately submitted. ... Determination The ITRD Representatives will inform the Applicant of whether ITRD would consider the issue further in the context of an advance income tax ruling. … Any comments provided by ITRD Representatives will not be binding on the Canada Revenue Agency. ...