Search - ”资源化利用" resource

CALU Roundtable May 7 – 8, 2012 ROUNDTABLE QUESTION # 1(b) Q.1(b) Income Tax Folio Initiative The Income Tax Rulings Directorate has announced that it will be updating the technical content and improving the functionality of Interpretation Bulletins through the creation of a replacement technical tax publication called the Income Tax Folios. ... Could you comment on the priority status the following seven Bulletins identified by CALU in its response to this feedback request: IT-85R2- Health and Welfare Trusts IT 223 – Overhead Expense Insurance IT 244 – Gifts of Life Insurance as Charitable Donations IT 430R3 – Life Insurance Proceeds Received by a Private Corporation IT 447- Residence of a Trust or Estate IT 449R – Meaning of Vested Indefeasibly IT 533 – Interest Deductibility A.1(b) The Income Tax Rulings Directorate recognizes the value in being able to consult an authoritative source of technical tax information and the CRA’s interpretation of the legislation it administers. ... We note that even priority topics will take time to address and specific timelines will depend on the complexity of the particular topic as well as available resources. ...

LLPs & LLLPs At the 2016 Society of Trust and Estate Practitioners (“STEP”) and the International Fiscal Association (“IFA”) CRA Roundtable, the CRA announced that it considers Florida and Delaware limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) to generally be corporations for the purposes of Canadian income tax law. ... CRA resources are available to taxpayers when they have doubts as to their filing positions, but the CRA can’t be considered to have assented to taxpayer filing positions indirectly through so-called “negative assurance”. ...

THE INSTITUTE OF CHARTERED ACCOUNTANTS OF NOVA SCOTIA ROUND TABLE FEBRUARY 1994 Question # 7 ANNUITIES PURCHASED FROM CHARITABLE ORGANIZATIONS The Department's position as outlined in Interpretation Bulletin IT-111R allows a charity to pay an amount as an annuity back to a donor who has made a contribution to the charity. ... The charity may simply make payments from its resources or it may purchase an annuity from a recognized annuity issuer, either in the name of the donor or in its own name with a direction to pay in favour of the donor. ...

Reasons: Due to delay in the discussions between the RPD and other government regulators relative to their pension benefits standards legislation. 2020 CALU CRA Roundtable – July 2020 Question 9- CRA Newsletter on section 147.4 annuities Background In December 2018, the Registered Plans Directorate (RPD) issued a draft newsletter for industry consultation relating to registered annuities issued under section 147.4, Conference for Advanced Life Underwriting (CALU) welcomed the efforts of the RPD to provide more clarity on what conditions need to be satisfied in order for a third-party annuity, which is acquired in satisfaction of a member's rights to benefits under a registered pension plan, to qualify under section 147.4. ... These discussions have recently concluded and, subject to resource availability caused by the current pandemic, RPD anticipates that the final version of the Newsletter will be on the CRA website in the summer of 2020. ...

If additional resources are necessary for this endeavor, has CRA secured them? ... Among the publications that emerged as the most in demand were those related to: the medical expense tax credit, education and tuition tax credits, along with scholarships and bursaries, interest deductibility, foreign exchange gains and losses, legal and accounting fees, health and welfare trusts, determining residency, residence of a trust, employee stock options and damages & settlements. ... Income Tax Folios will be a valuable resource for years to come. ...

TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF- CONGRÈS 2008 Question 42 Exemption de production des déclarations de renseignements des sociétés de personnes Selon la Circulaire d'information IC-89-5R de l'ARC du 1er décembre 1994, les exemptions de production de la déclaration de renseignements des sociétés de personnes, T5013, étaient les suivantes (à cette époque le terme " société " voulait dire " société de personnes "): a) Les sociétés comptant au plus cinq associés pendant tout l'exercice financier, durant lequel aucun associé n'est une autre société. Cette exemption se formulait auparavant " Les sociétés comptant au plus cinq associés ". ... The limited partnership must file Forms T102 Summary and T102 Supplementaries (Resource Expenses Attributable to Partners) and attach a copy of the financial statements of the limited partnership for the fiscal period to the T102 Summary. ...

Reasons: See below. 2010 CTF Conference – November 28, 2010 Flow-through Shares Question 19 Does the CRA consider that Canadian exploration expenses (CEE) can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share under both the current and proposed definitions of "flow-through share" in subsection 66(15)? ... Pursuant to paragraph (b) of both the current and proposed definitions of "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share, as the case may be. ...

In its response, the Canada Revenue Agency (the “CRA”) extends the principles of Daishowa to the resource industry. ... Canadian Western Natural Gas, Light, Heat & Power Co. ((1922) 69 DLR 401 (Alta SC (AD)). ... George Thompson & Company, Limited (1927), 13 TC 83 (Eng. KB) (“Scales”) sets out the test for the determination of whether certain operations are a separate business. ...

Position: Three changes will be highlighted with general comments (1) Mickey Sarazin as the new DG, (2) the new Folios project, (3) introduction of the email service Reasons: General comments provided STEP CRA Roundtable – June 2012 QUESTION 16 Can the CRA provide an update on recent administrative changes within the Income Tax Rulings Directorate that may be of interest to this audience? ... Sarazin plans to work with all staff and managers within the Directorate to find improvements in our business processes to maximize our limited resources to better meet clients’ needs. ... This service is not intended to replace technical interpretation letters issued on various provisions of the Income Tax Act – but rather to provide a vehicle to efficiently address general questions of interpretation or to provide responses to issues which the Directorate has previously addressed. ...

STEP CRA Roundtable – June 10, 2016 Question 15. Trust and Estate Issues Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ... Subsection 159(6.1) election: In external interpretation 2015-0594201E5 we were asked whether an election pursuant to subsection 159(6.1) of the Income Tax Act can be made where a liability for tax arises from a deemed disposition of resource property. ...