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Chapter 20 - 8517 – Transfer – Defined Benefit to Money Purchase

Chapter 20- 8517 – Transfer – Defined Benefit to Money Purchase On this page... 20.1 8517(1) – Prescribed Amount 20.2 8517(2) – Minimum Prescribed Amount 20.3 8517(3), (3.001), (3.01), (3.02) – Underfunded Pension 20.4 8517(3.1) – Benefits Provided with Surplus on Wind-up 20.5 8517(4) – Amounts of Lifetime Retirement Benefits Commuted 20.6 8517(5) – Normalized Pension 20.1 8517(1) – Prescribed Amount The prescribed amount is a maximum that limits the amount that may be transferred to an RRSP, RRIF, or MP provision from a DB provision of an RPP under subsection 147.3(4) of the Act. ... Cross references: Transfer – Defined Benefit to Money Purchase, RRSP or RRIF – 147.3(4) Lump Sum Payments on Termination – 8503(2)(h) Commutation of Benefits – 8503(2)(m) Commutation of LRBs – 8503(7) Newsletter No. 94-2, Technical Questions and Answers 20.2 8517(2) – Minimum Prescribed Amount Subsection 8517(2) of the Regulations allows the greater of the amount determined under subsection 8517(1) and the amount in the member’s net contribution account, as defined in subsection 8503(1), to be transferred on a tax deferred basis. ... Cross reference: Designated Laws – 8513 Page details 2020-07-06 ...

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.” ...

Felty v. Ernst & Young LLP, 2015 BCCA 445 -- summary under Agency

Ernst & Young LLP, 2015 BCCA 445-- summary under Agency Summary Under Tax Topics- General Concepts- Agency presumption that law firm agreement binds client The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ... In finding that the appellant was bound by the engagement agreement, Newbury JA applied (at para. 38) the principle in Shaw, Salter & Plommer v. Phipps & Cosgrove (1926) 37 B.C.R. 184 “that as a general rule, solicitors will be taken to be contracting on behalf of their clients in the course of their practice.” ...

Offshore Compliance Advisory Committee – Agenda – February 3, 2017

Offshore Compliance Advisory Committee – Agenda – February 3, 2017 Friday, February 3, 2017 9:00 a.m.- 4:30 p.m. ... Audit Agreement Policy Presentation & roundtable discussion Lisa Anawati / Alexandra MacLean 12:00 7. ... Audit Agreement Policy- continued Roundtable discussion & scenarios All 14:30 9. ...

19 May 2017 GST/HST Interpretation 178323 - – […] [Registration of a] Limited Partnership

Section […] of the [LP2] Agreement more specifically explains that [LP1] will make its capital contribution to [LP2] by contributing $[…] cash firstly and fund the remaining balance of its capital contribution of $[…] by way of a set-off of the amount that will be payable on the second closing date by [LP2] to [LP1] pursuant to the […]. 5. ... Subsection […] of the [LP2] Agreement, under the heading […], includes distributions payable by [LP2] to [LP1] of $[…], representing a return of [LP1]’s Capital Contribution in the amount of the cash reimbursement which [LP2] is required to make pursuant to the […] for certain expenses incurred in the course of issuing Partnership interests (such amount hereinafter referred to as the […]). ... Factors to consider include, but are not limited to, the following: * the terms of the partnership agreement; * the nature of the action taken by the partner; and * the partner's ordinary course of conduct. ...

Mussalli – Federal Court of Australia finds that a partial rent prepayment was a capital expenditure

In finding that the rent prepayments were capital expenditures, so that such deduction was not permitted, Jagot J stated: [T]he payments … were … a one off, lump sum, non-refundable payment made to secure an enduring advantage (the right to pay the lesser percentage rent) for the term of the [leases] and most likely the term of any renewal of the [leases]. ... As a matter of substance the payments, although called the prepayment of rent, did not involve the payment of rent at all. … … What [the trust] acquired through the payments was a business with a different structure, a business in which the percentage rent payable was permanently reduced …. … The non-refundable nature of the payments suggests that they were not made to secure the right to occupy the premises under the lease and, rather, were capital in nature. ... Summary of Mussalli v Commissioner of Taxation [2020] FCA 544 under s. 18(1)(b) – Capital expenditure v. expense – Contract purchases or prepayments. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ("Application of S. 10.1, Sch. VI, P. V – Service Related to Intangible Personal Property") -- summary under Section 10.1

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ... V – Service Related to Intangible Personal Property")-- summary under Section 10.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 10.1 A Canadian GST-registered supplier sells custom software that it has been using to perform a service electronically, with such supplies being made in Canada. ...

Canada (Attorney-General) v. Brogan Family Trust, 2014 ONSC 6354 -- summary under Rectification & Rescission

Brogan Family Trust, 2014 ONSC 6354-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no obligation to notify Crown if tax liability which was relieved has not been assessed The respondent family trust obtained a rectification order, to permit trust distributions to minor grandchildren beneficiaries, on 26 November 2010, which was shortly after a sale of a business by the trust. ... In dismissing this motion, Ray J stated (at para. 13): I am not persuaded that… CCRA [sic] was affected by the order of McLean, J. … [After citing Canada v. ... Richter & Associates, [2000] OJ No. 2073 (Ont SC) aff'd [2001] OJ No. 1087 (Ont CA)]. ...

Appendix A – Data elements – TFSA individual electronic record

For reporting year 2016, file the individual record under John's name and SIN for TFSA contract 12345, and indicate " N " for no in the " Successor holder account " field. ... Total holder transfer in – Marriage breakdown – Fair market value Enter the total of all transfers in. Report type code Original = O Amendment = A Cancel = C An amended return cannot contain an original slip. ...

Mold Leaders Inc. v. The King, 2023 TCC 127 -- summary under Scientific Research & Experimental Development

The King, 2023 TCC 127-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development challenging engineering involving standard procedures was not SR&ED The taxpayer (ML), carried on a business of the custom designing and making of injection molding including for the automotive industry. ... [His] …answers did not reveal or identify technological uncertainties being addressed in a scientific manner. … ML’s favoured approach … was to basically try various options, anticipating that one likely would work. For me that is indicative of routine engineering or standard procedures. … ...

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