Search - 丁薛祥 2005年年龄

Tax years after 2005 – eligible and non-eligible dividends 2.48 To improve integration and neutrality in the tax system, an enhanced dividend gross-up and enhanced dividend tax credit (the enhanced dividend gross-up and dividend tax credit) were introduced for qualifying dividends paid after 2005. ... It is defined in subsection 89(1) and the calculation applies to tax years that end after 2005. ... Variables G and H reduce a non-CCPC's LRIP. 2.122 The calculation of LRIP applies for tax years that end after 2005. ...

Table of contents Discussion and interpretation Overview of the capital dividend account Capital dividend account – private corporation qualification Capital dividend account – election Election under subsection 83(2) and its effects Late-filed elections Capital dividend account – components General discussion of the CDA balance determination CDA Component 1 – non-taxable portion of capital gains CDA Component 2 – capital dividends received by the corporation CDA Component 3 – eligible capital amounts CDA Component 4 – life insurance policy proceeds CDA Component 5 – trust distributions CDA Component 6 – capital dividends payable Special rules Amalgamation or winding-up Payments in kind and deemed dividend payments Excessive elections Overstatements Additional tax on excessive elections Election to avoid additional tax Anti-avoidance rule Application Reference History Discussion and interpretation Overview of the capital dividend account 1.1 This section will give the reader an overview and general description of the capital dividend account (CDA) and the mechanism to pay tax-free dividends from that account. ... CDA Component 5 – trust distributions 1.73 This paragraph has been deleted. ... The non-deductible portion of the capital loss of Corporation B is $75,000. $50,000 – $75,000 = – $25,000 Component 1 = NIL (because Component 1 cannot be a negative amount) Component 3 Amount included in income of Corporation A pursuant to paragraph 14(1)(b) (see ¶ 1.54) Component 3 = $25,000 Component 4 Net proceeds of a life insurance policy received by Corporation B Component 4 = $40,000 Calculation of CDA balance of Amalco: Component 1 + Component 3 + Component 4 = $65,000 In the first tax year after amalgamation, Amalco realizes a capital gain of $90,000, the non-taxable portion of which is $45,000. ...

In 2005, Mr. X died and the house was transferred to a spousal trust for Mrs. ... X had not died (and if he had sold his house in 2005), he could have designated it as his principal residence for any of the years 1995 to 2005 inclusive. ... X owned it, that is, 1995 to 2005 inclusive, in accordance with the rule described in ¶2.70(a) above. ...

K incurs an ABIL in the amount of $60,000 in the 2005 tax year. Ten years later, at the end of 2015, only $56,000 of the ABIL has been used as a non-capital loss. ... The capital gains inclusion rate for the 1999 tax year was ¾. The capital gains inclusion rate for the 2015 tax year is ½. ... For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163, 2005 DTC 5281). ...

For more information about what is considered to be a research grant, see ¶ 3.58. ... For more information about amounts taxed under paragraph 56(1)(r), see ¶ 3.79. 3.22 In Simser v The Queen, 2004 FCA 414, 2005 DTC 5001, the Federal Court of Appeal held that funds received by a taxpayer pursuant to the Special Opportunities Grant for Disabled Students with Permanent Disabilities (a program funded jointly by the Ministry of Education and Training for Ontario and the Department of Employment and Social Development) constituted a bursary within the meaning of paragraph 56(1)(n). ... A prize that is not described by subparagraph 56(1)(n)(i) is considered to be a windfall and is not required to be included in income unless it is also a business receipt (see ¶ 3.55) or income from employment (see ¶ 3.54). ...

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