Search - ”资源化利用" resource

Trusts and Estates – Recent Legislative Changes [no response] This question was not addressed by the CRA. ... CRA Response The CRA continues to focus its audit resources on files with the highest risk and it does so through business intelligence. ... University & Public College Meal Plans [no response] This question was not addressed by the CRA. ...

Various Questions Relating to T1134 Reporting (for 2021 and later taxation years) (i) Part I Section 3E – Lower tier non-controlled foreign affiliates (Table) (ii) Part II Section 1D – Foreign Affiliate Dumping Rules (Table) (iii) Part II Section 3A – Surplus Accounts – 4. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ... Question 14: Charities – Transfer of Property to a Grantee Organization Background Recently, the Act was amended to permit Canadian registered charities to make disbursements by way of a gift or by otherwise making resources available to a “grantee organization” which is defined to include a person, club, society, association or organization or prescribed entity, but not a qualified donee. ...

The presenters were: Gord Parr, Director, Large Business Audit Division, International and Large Business Directorate, Compliance Programs Branch Andrew Kingissepp, Partner, Taxation, Osler, Hoskin & Harcourt LLP Certain questions that briefly introduced the topics (e.g. ... Audit Resources Kingissepp: I think part of it is that the Audit resources are perhaps perceived as being more than at the Appeals level. ... Parr: Yes- generally, there are more resources within the Compliance Programs Branch than Appeals Branch. ...

There have been recent federal government announcements to commit more resources to combat, among other things, international tax avoidance. ... Official Response 26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution 8) Borrowing to return capital and s. 95(2)(a)(ii)(B) A Canadian corporation (“ Canco ”) owns all the shares of a foreign affiliate (“ FA1 ”) which in turn owns all the shares of another foreign affiliate (“ FA2 ”). Canco also owns all the shares of another foreign affiliate (“ FA3 ”). ...

Resource deduction addback Repetto: Some submissions have noted that, while there is an add-back for CCA deductions in the adjusted taxable income computation, there is no such add-back for deductions in respect of various resource expense pools. ... However, in light of the submissions we have received, we are now considering potentially providing an add-back in respect of resource expense pool deductions. ... McGowan: All of the following examples are subject to solicitor-client privilege – reporting would not be required where it would breach privilege. ...

Email this Content 17 May 2023 IFA Roundtable- Official Response Question 1: Section 247 & Recent Changes Regarding Stock-Based Compensation CRA Response Question 2: Ukraine/Russia Reporting Requirements CRA Response Question 3: T1134 Supplement Disclosure on Dividends CRA Response Question 3(1) Question 3(2) Question 4: Canada-Barbados Income Tax Convention – “Special Tax Benefit” Question CRA Response Question 5: Canadian tax issues for U.S. resident employers of Canadian resident employees under remote work arrangements CRA Response Question 6: Application of the Canada-U.S. ... Question 4: Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ... An accountant or a human resource professional providing services only to USco could be an example of this. ...

LLPs & LLLPs CRA Response Question 11: Computation of Earnings for a Disregarded U.S. ... Poulin wanted to leave Amiante, selling his interest in it at the best price and under the most optimal possible conditions — one of which was to benefit from his capital gains deduction. ... CRA resources are available to taxpayers when they have doubts as to their filing positions, but the CRA can’t be considered to have16 assented to taxpayer filing positions indirectly through so-called “negative assurance”. ...

In the second return, the following will have to be reported: Taxable dividend received (before the application of s. 55(2) $400,000 Part IV tax paid $153,333 RDTOH Total of: Part I refundable tax on capital gain; $24,533 = $160,000 • 50% • 30.66% Total RDTOH $177,866 Dividend paid $160,000 Dividend refund Lesser of: RDTOH ($177,866) and 38.33% of $160,000 ($61,333) $61,333 Note that 2 returns, not more, are needed to be filed to reflect the application of 55(2) and that there is no circular calculation involved. ... The initial folios workload was prioritized for action based on considerations that included: feedback received through internal and external consultations to identify the public need for guidance in each technical subject area; and the availability of resources to prepare the required updates. ... Question 16: Medical Expenses – Medical Assistance in Dying The Supreme Court recently issued its ruling in Carter v. ...

That is true – TEBA is used more to measure the performance of Tax Services Offices, and different programs, and to decide where to allocate resources. ... It’s a challenge – when you are auditing, you don’t know what you don’t know. ... We are, therefore, providing more resources to the Department of Justice for that purpose. ...

Would the Resource Rights Vendor thereby be considered to acquire Resource Rights for taxable (re-)supply for (not nominal) consideration in the course of the Resource Rights Vendor’s business (that is, commercial activity), so that it would be entitled to claim full ITCs for the GST/HST payable on the acquisition? ... CRA Comments If a supplier (re)supplies Resource Rights, both the supplier’s acquisition and supply of the Resource Rights would generally be deemed not to be supplies under subsection 162(2) of the Excise Tax Act (ETA). ... Therefore, if legal ownership is not transferred to the particular individual with whom the builder entered into the agreement of purchase and sale – which seems to be the case in the situation described, as ownership of the new house seems to be transferred to the corporation as bare trustee – then the requirement in paragraph 254(2)(e) of the ETA is not satisfied and the Minister cannot pay a new housing rebate under subsection 254(2). ...