Search - 三河市 市委书记 现任

Herbert, "Trusts Holding Shares For Employees", draft 2023 CTF Annual Conference paper-- summary under Employee Benefit Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Employee Benefit Plan Use of phantom plans as EPBs (pp. 9 – 14) An employee benefit plan (EBP) can be used to acquire employer or parent company shares on the open market in order to settle phantom share awards (payable in cash or in shares), such as restricted or performance share units (RSUs or PSUs). ... The carve-out in s. 12(1)(n.1) for amounts included in an employer’s income under s. 12(1)(n) is an implicit acknowledgement that an employer can be a beneficiary – which can facilitate liquidation of the trust. ...

Kandev, "NIB Loan to Non-FA-Related Non-Resident", Canadian Tax Highlights, Vol.26, No. 4, April 2018, p. 5-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Interest-free loan from a CFA of Canco to a NR sister of Canco 2015-0622751I7 … analyzed the tax consequences of a foreign parent, its wholly owned Canadian holdco, and the Canadian holdco's Canadian subsidiary (Canco). ... Absent such explicit provision, basic principles of territoriality dictate that Canada cannot tax the amount (Oceanspan …) ...

[fn 49: … 2012-0440101E5] This consequence seems inappropriate given that individuals would not be subject to branch tax had they carried on the branch business directly. ... For their part, retirement compensation arrangements are not exempt from tax [fn 61: … 2009-0327031C6]. ... The same rationale is applicable to royalties and service fees, as confirmed by some rulings [fn 67:… 2009-0348581R3]. … [T]he same conclusion was given where the shareholders of the ULC were two sister S-corporations held by the same U.S. shareholder [fn 68: … 2010-0376751E5]. ...

Proposed Subsection 18.4(17) & Security Interests”) The “specified entity” rules should contain an express exclusion for arrangements that secure indebtedness, equivalent to the exclusion provided in subsection 18(5.1). ...

Bank & Trust Co. v. Eelman [(1936), 183 A. 677 at 678-9)] the New Jersey court identifies as the essence of a debt the fact that a sum is owed [fn. 8 The New Jersey court apparently means "owed" in the sense that the sum can be successfully sued for. ... Diewold, [1941] S.C.R. 35 ….] Narrower view restricting to contract (pp. 13-14) A narrower view of debt is to restrict it to money obligations arising out of express or implied contract, including quantum meruit. ...

Ralph Neville, "Acquisition of Control and Corporate Losses", 1992 Conference Report (CTF), C. 25-- summary under Paragraph 13(7)(f) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(f) ½ step-up rule does not apply for capital gains purposes (p.25:7) If a designation is made under paragraph 111(4)(e) with respect to depreciable property, paragraph 13(7)(f) of the Act deems the capital cost of the property, for the purposes of future capital cost allowance (CCA) and recapture, to be the capital cost of the property before the deemed disposition plus three-quarters of the excess of the proceeds of disposition over the capital cost. ...

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022-- summary under Subsection 18.2(12) Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(12) Effective 30% capacity generated by interest and financing revenues (IFR) from NAL non-resident – even if paid by its Cdn. branch (p. 3) [I]nterest received from any non-arm’s length nonresident appears to be excluded from IFR. ...

See, also, Black & Decker Manufacturing Co. v. R., [1975] 1. S.C.R. 411 (S.C.C.).] ...

Ernst & Young LLP (2015 BCCA 445), the BCCA decided that a limitation of liability clause in a retainer agreement for tax advice rendered by an accounting firm limited the accounting firm's liability and was enforceable against the plaintiff, Ms. ...

.-- summary under Article 29B Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29B Treaty relief from residency requirement in 70(6) – but “will” requirement (p. 171) Subsection 70(6) applies to a transfer to a taxpayers spouse only when the taxpayer and the spouse were resident in Canada immediately before the taxpayer's death. ...