Search - стрим ешмек шешу

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) split income rules do not apply to preferred beneficiary income The definition of split income includes trust income distributions under s. 104(13) but not preferred beneficiary amounts under s. 104(14). ...

5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit-- summary under Paragraph 125(3.2)(d) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(3.2)- Paragraph 125(3.2)(d) business limit allocation may be amended within statute-barring period In essentially confirming 2009-0351721E5 to the effect that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s provided that the amended allocation agreement does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred, CRA stated: [P]aragraph 125(3.2)(d) provides that both CCPCs must file a prescribed form with the Minister in their return of income for their respective taxation years for the assignment to be valid. ...

1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) right to accrued but undeclared dividends was not a separate eligible property from the preferred shares Before indicating that a preferred share with accrued cumulative dividends could be transferred by an individual to a holding corporation under s. 85(1) or exchanged for other shares of the corporation pursuant to a reorganization of capital described in s. 86(1) without the accrued dividends being recognized as income, Revenue Canada rejected the position that such accrued dividends would be an eligible property separate form the shares themselves, stating: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) "It is a question of fact whether a taxpayer, who is a resident of a foreign country and who is present in Canada for more 182 days in a year, sojourns in Canada for more than 182 days in that year. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 "Where a U.S. resident who is not a factual or deemed resident of Canada exercises his employment in Canada, his employer... is required to withhold source deductions in respect of the employment under subsection 153(1) of the Act even if the remuneration received by such an individual is exempt from Canadian taxation by virtue of paragraph 2 of Article XV of the Convention. ...

16 July 1996 External T.I. 9604915- 55(2)-NOT APPLY WHERE SALE & REDMPTION DIFFERENT SERIES.-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Where preferred shares issued by Newco on the roll-in to Newco of shares of Opco, have a dividend entitlement equal to dividends received by Newco on the shares of Opco, and to proceeds received by Newco on the sale of shares of Opco to the extent of the gain realized by Newco, but with the redemption amount of the shares being reduced on a dollar-for-dollar basis by the amount of the dividends paid out of such gain. ...

7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business principal purpose means main or chief objective In the course of a general discussion as to whether a Canadian-controlled private corporation with rental properties carried on an active business, CRA stated (before referring to the more-than-five full time employee test): A "specified investment business" is essentially a business, including a business of leasing real or immovable property, the principal purpose of which is to derive income from property, including rents. ...

30 July 2003 Internal T.I. 2003-0024037- ACB OF LAND & BUILDING-- summary under Paragraph 20(1)(cc) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(cc) ss. 20(1)(cc), (dd) and (ee) deductions for amounts otherwise on capital account Respecting the determination of ACB of where a medical doctor acquired land and constructed a building that is used to earn business income, CRA stated: [G]enerally all of the outlays and expenses incurred in respect of the acquisition of the land and construction of the building will be considered incurred on account of capital, and consequently, will constitute part of the ACB of the particular properties. ...

8 December 2003 Internal T.I. 2003-0042537 F- CIEE & SRAS-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) lay-off due to SARS did not qualify as an absence After taking leave in Canada in accordance with the terms of their employment regarding an offshore project, the employees’ return to the project was refused by the local authorities due to the intervening outbreak of the SARS epidemic, so that they were laid off for some time. ...