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Decision summary

Bosa v Canada, 2025 BCSC 1284 -- summary under Rectification & Rescission

Bosa v Canada, 2025 BCSC 1284-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission BCSC lacked the jurisdiction to consider a request to rectify a clause in a family trust indenture whose interpretation was at issue in an impending TCC appeal The petitioners were the beneficiaries of a family trust, who sought to rectify the terms of the Trust Indenture to clarify that the assets of the trust had vested indefeasibly in them on the date defined in the Trust Indenture as the "Distribution Date," which occurred approximately 10 months before the 21st anniversary of the formation of the trust. ... Canada 2013 ABQB 489, at para. 61. The interpretation of the Trust Indenture which they [the petitioners] urge me to adopt is based on the same arguments that the Reassessment officer considered and rejected. Those arguments are the subject of the appeal to the Tax Court …. In further finding that, even if she had jurisdiction, rectification would not be appropriately granted, she stated (at para. 58) that “[i]t is well established that equitable relief is not available to avoid unanticipated adverse tax consequences which arise from the ordinary operation of the Income Tax Act Collins Family Trust ….. ...
GST/HST Ruling

19 August 2011 GST/HST Ruling 137315 - Application of GST/HST to [...] [ABC's] [...] [Fruit] Juice

19 August 2011 GST/HST Ruling 137315- Application of GST/HST to [...] ... The Product is [...] [Fruit] juice. 2. The Product is sold in 500 ml [...] bottles and is non-carbonated. 3. ... The label states [...]. 5. On the website[...] it is stated that: a) [...] ...
Old website (cra-arc.gc.ca)

Appendix B – Data elements – TFSA return summary

Appendix B Data elements TFSA return summary When a monetary value is required you must report the amount in Canadian dollars and cents. ... Summary type code Original = O Amendment = A An amended return cannot contain an original slip. ... Filer name line 1 If an ampersand (&) is used in the name area, enter as "&amp. ...
Current CRA website

Statement of account for current source deductions – Regular and quarterly remitters – PD7A

Remit (pay) payroll deductions and contributions Types of remitters When to remit (pay) Payroll correspondence you need to remit (pay) Statement of account for current source deductions Regular and quarterly remitters PD7A Statement of account for current source deductions Accelerated remitters PD7A(TM) Remittance voucher booklets for accelerated remitters PD7A-RB Remittance voucher for Payment on Filing (PoF) Source Deductions PD7R Request for tax deductions, CPP and EI information if you remit late PD1114 Statement of account and partial payment for arrears balance remittance voucher PD7D(AR) Statement of account and payment on existing balance remittance voucher PD7D(X) How to remit (pay) Confirm your remittance (payment) and view statements Make corrections after you remit (pay) Statement of account for current source deductions Regular and quarterly remitters PD7A On this page What is a PD7A How often is a PD7A sent What to do if you received a PD7A What is a PD7A The PD7A is sent to regular and quarterly remitters. ... YOUR CONTACT INFORMATION Appears in the left corner” “2. STATEMENT DATE INFORMATION Organized so you can easily identify your statement details” “3. ACTION YOU NEED TO TAKE Provides your information and if actions are required” “4. ...
Current CRA website

Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide – Chapter 5 – Capital cost allowance

She does this as follows: GST at 5% of $37,000 = $1,850 PST at 8% of $37,000 = $2,960 Therefore, Vivienne's capital cost is $41,810 ($37,000 + $1,850 + $2,960). ... Example First-year enhanced allowance Acquisition cost $65,000 First-year CCA $61,000 × 75% = $45,750 Undepreciated capital cost (UCC) $61,000 $45,750 = $15,250 Proceeds of disposition $30,000 Part of proceeds of disposition to be deducted from the UCC $30,000 × ($45,750 ÷ $65,000) = $21,115 Class 55 (40%) Include in Class 55 zero-emission vehicles that would normally be included in Class 16. ... Capital cost calculation Change in use Actual cost of the property $ Blank space for dollar value Line 1 FMV of the property $ Blank space for dollar value Line 2 Amount from line 1 $ Blank space for dollar value Line 3 Line 2 minus line 3 (if negative, enter "0") $ Blank space for dollar value Line 4 Enter all capital gains deductions claimed for the capital gains related to the depreciable property $ Blank space for dollar value × 2 = $ Blank space for dollar value Line 5 Line 4 minus line 5 (if negative, enter "0") $ Blank space for dollar value × ½ = $ Blank space for dollar value Line 6 Capital cost (line 1 plus line 6) $ Blank space for dollar value Line 7 Enter the capital cost of the property from line 7 in column 3 of Area B or C. ...
GST/HST Ruling

14 July 2022 GST/HST Ruling 193655a - – […] Tax status of common expense fees

The Corporation’s parking building is in very close proximity to [#] […] residential condominium buildings, which also have parking slips. ... There is a shared facilities agreement between the Corporation and the [#] neighbouring condominium corporations to acknowledge shared spaces with respect to the underground parking linked under the […] buildings. ... The Corporation’s only supplies are the supply of parking slips and bicycle storage units to residents of the [#] neighbouring condominium buildings. […]. ...
Old website (cra-arc.gc.ca)

Example – Instalment base – Amalgamations

Example Instalment base Amalgamations Example Corporations A, B and C each have a tax year that begins on January 1 st and ends on December 31 st. ... This amount is the total of the predecessor corporations' tax payable for 2015 ($4,000 + $5,000 + $6,000) for their last tax year before amalgamation. $7,500 for the second instalment base amount for the successor's 2016 tax year. This amount is the total of the predecessor corporations' first instalment base amounts ($2,000 + $2,500 + $3,000) for the 2015 tax year. ...
Technical Interpretation - External summary

25 January 2018 External T.I. 2017-0709241E5 - Subsections 125(3.2) & 125(5.1) -- summary under Subsection 125(5.1)

25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations exceeds $10 million [so that] once the taxable capital reaches $15 million its business limit would be zero,” CRA stated:. ...
Technical Interpretation - Internal summary

6 September 2023 Internal T.I. 2019-0805481I7 - Interaction of 17.1(1) & 247(2) -- summary under Subsection 247(2.1)

6 September 2023 Internal T.I. 2019-0805481I7- Interaction of 17.1(1) & 247(2)-- summary under Subsection 247(2.1) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2.1) there is no conflict in applying both ss. 17.1 and 247(2) to impute interest on a PLOI A non-resident corporation (Parent2) which, through a wholly-owned non-resident subsidiary, was the sole shareholder of a corporation resident in Canada (“CRIC”), received various unsecured loans from the CRIC, which bore interest at a floating rate equal to the prescribed rate under Reg. 4301(b.1), payable not less than annually. ... In short subsection 247(2), which was broadly worded to embody the arm’s length principle, was meant to apply to all cross-border transactions, arrangements or events, including financial transactions, between non-arm’s length persons or partnerships, unless a specific exclusion applies. [See] 2017-0691071C6 …. ...
Technical Interpretation - Internal

15 January 2004 Internal T.I. 2003-0026827 - Non-resident & Tuition & Educations credits

15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits Also released under document number 2003-00268270. ... January 15, 2004 ASSESSMENT & COLLECTIONS BRANCH HEADQUARTERS Individual Returns & Payment Processing Income Tax Rulings Directorate Directorate S. ...

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