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Decision summary
FNF Canada Company v. Canada (Attorney General), 2012 NSSC 217 -- summary under Rectification & Rescission
Canada (Attorney General), 2012 NSSC 217-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission proposed rectification inconsistent with financial statements The applicant, incorporated by a U.S. corporation ("Fidelity National"), received $23,659,000 from Fidelity National in order to finance its business in Nova Scotia. ...
Decision summary
Winclare Management Services Ltd v. Canada (Attorney General), 2009 CanLII 18234 (Ont SC) -- summary under Rectification & Rescission
Canada (Attorney General), 2009 CanLII 18234 (Ont SC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission unopposed application to reduce capital dividend to CDA balance The directors of the taxpayer mistakenly declared a dividend in an amount exceeding its capital dividend account, and it elected under s. 83(2) to treat it as capital dividend. ...
Decision summary
Les Structures G.B. Inc. v. A.G. Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134 -- summary under Rectification & Rescission
Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...
Decision summary
Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77 -- summary under Business
Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business non-trading business At issue was whether two partnerships which acquired interests in films and immediately leased their acquired interest for fixed, increasing, secured and guaranteed rental payments for a 15 year period, and were acknowledged to have a business, were carrying on a trade. ... " In affirming the finding below (initially made by the First-Tier Tribunal) that the partnerships were not carrying on a trade, Arden LJ stated (at paras 59, 61, 66): … [I]t is now clear from Eclipse … that the question whether what the taxpayer actually did constitutes a trade has to be answered by standing back and looking at the whole picture…. … The [FTT’s] overall assessment of the commercial nature of the agreements as the payment of a lump sum in return for a series of fixed payments over 15 years…was not a crude conclusion based on an impermissible transformation of the taxpayers' activities into an economic equivalent, but rather a way of expressing the ultimate inference of fact which they drew from the totality of the primary facts which they had found. ...
Current CRA website
T2 Corporation – Income Tax Guide – 2016
T2 Corporation – Income Tax Guide – 2016 T4012(E) Rev. 16 If you are blind or partially sighted, you can get our publications in braille, large print, etext, or MP3 by going to About multiple formats. ... La version française de ce guide est intitulée Guide T2 – Déclaration de revenus des sociétés. ... Before you start Chapter 1 – Page 1 of the T2 return Identification Chapter 2 – Page 2 of the T2 return Attachments Information schedules and forms Calculation schedules Chapter 3 – Page 3 of the T2 return Attachments Additional information Calculating net income or loss Losses How to complete Schedule 4, Corporation Loss Continuity and Application Taxable income Chapter 4 – Page 4 of the T2 return Small business deduction Chapter 5 – Page 5 of the T2 return General tax reduction Chapter 6 – Pages 6 and 7 of the T2 return Refundable portion of Part I tax Refundable dividend tax on hand Dividend refund Chapter 7 – Page 8 of the T2 return Part I tax Chapter 8 – Page 9 of the T2 return Summary of tax and credits Federal tax Provincial and territorial tax Other credits Refund or payment Payment of balance owing Direct deposit request Mandatory electronic filing for tax preparers Certification Language of correspondence Related forms and publications List of federal and provincial or territorial corporation schedules and forms Online services Handling business taxes online Electronic payments For more information What if you need help? ...
Technical Interpretation - Internal summary
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136) -- summary under Payment & Receipt
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...
Technical Interpretation - External summary
15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208) -- summary under Payment & Receipt
15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt No payment will be considered to occur pursuant to an agreement between the parties to the effect that interest on a promissory note will be deemed to be paid and then loaned back to the borrower. ...
Technical Interpretation - Internal summary
19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops") -- summary under Payment & Receipt
"Patronage Dividends Paid by Non Co-ops")-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Payment of a patronage dividend may be effected by the issuance of shares or debt instruments, where such an arrangement is authorized by the customer. ...
Technical Interpretation - External summary
31 August 1992 T.I. (Tax Window, No. 24, p. 8, ¶2184) -- summary under Payment & Receipt
(Tax Window, No. 24, p. 8, ¶2184)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A direct payment by a non-resident to Revenue Canada of a tax liability of a related Canadian corporation would entail the receipt of an amount by the Canadian corporation for purposes of s. 12(1)(x). ...
Technical Interpretation - External summary
7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066) -- summary under Payment & Receipt
7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Because the function of a journal entry is to record a transaction rather than to make it legally effective, the reclassification of a shareholder's loan into remuneration payable by a journal entry would not be considered to be payment of the remuneration. ...