Search - 三河市 市委书记 现任

12 March 2015 External T.I. 2014-0541991E5- Objection – Eligible Dividend Designation Principal Issues: 1. ... Ng (416) 512-4013 March 12, 2015 Dear XXXXXXXXXX, Re: Objection – Eligible Dividend Designation We are replying to your letter of August 1, 2014 in which you requested our comments with respect to the manner in which a taxpayer can make a late eligible dividend designation in the event that an assessment by the Canada Revenue Agency (the "CRA") which causes the taxpayer's general rate income pool ("GRIP") balance to increase is upheld at the end of the appeals process. ...

21 November 2005 External T.I. 2005-0143231E5- Terminal Charge / ONT Tax Reduction Unedited CRA Tags 6(2) Principal Issues: (a) The taxable status of a $XXXXXXXXXX terminal loss incurred by an employer in respect of a leased automobile at the end of the lease- should the entire amount of the terminal loss be included in the employee's income as a taxable benefit? ... Randy Hewlett XXXXXXXXXX 613-957-2049 2005-014323 November 21, 2005 Dear XXXXXXXXXX: Re: Automobile Benefit / Ontario Tax Reduction We are writing in response to your letter of April 30, 2005, which was sent to the CRA's Summerside Taxation Center. ...

29 October 2020 External T.I. 2020-0835681E5- Indian Act Exemption – Employment Income Unedited CRA Tags 81(1)(a); Indian Act s.87 Principal Issues: Are the employees (those working at the field office and those doing XXXXXXXXXX) exempt from income tax pursuant to Guideline 2? ... Gauthier October 29, 2020 Dear XXXXXXXXXX: Re: Indian Act Exemption for Employment – Guideline 2 This is in reply to your email dated January 7, 2020 where you asked whether employees of a partnership would be exempt from tax pursuant to Guideline 2 of the Indian Act Exemption for Employment Income Guidelines. ...

6 March 2023 External T.I. 2023-0960671E5- Carriage house & multigenerational home renos Unedited CRA Tags The definition of "qualifying renovation" and "secondary unit" in subsections 122.92(1). ... El-Kadi March 6, 2023 Dear XXXXXXXXXX: Re: Multigenerational home renovation tax credit – building a carriage house as secondary unit We are writing in response to your email of January 12, 2023, in which you asked whether the multigenerational home renovation tax credit (MGHRTC) would apply to the construction of an accessory dwelling unit such as carriage house or a laneway house. ...

19 December 2023 External T.I. 2023-0974871E5- METC-Interocular lens & prepaid medical expenses. ... Underhill, CPA, CGA December 19, 2023 Dear XXXXXXXXXX: Re: Amounts paid for interocular lens & prepaid medical expenses We are writing in response to your correspondence received on February 14, 2023, asking whether the cost you incurred for an interocular lens as part of cataract surgery qualifies as an eligible medical expense for the purposes of the medical expense tax credit (METC). ...

5 March 2024 External T.I. 2023-0962831E5- Active business income – Income from solar panels Unedited CRA Tags 125(1), 125(7) “income of the corporation for the year from an active business”, “active business carried on by a corporation”, “personal services business”, “specified investment business”, 129(4) “income or loss”, 248(1) “business”, “property" Principal Issues: Whether income earned by a corporation from selling electricity generated from solar panels would be active business income eligible for the small business deduction pursuant to subsection 125(1) of the Income Tax Act. ... XXXXXXXXXX Income Tax Rulings Directorate Ryan Wallace, CPA 2023-096283 March 5, 2024 Dear XXXXXXXXXX: Re: Active Business Income – Income received from selling electricity generated from solar panels We are writing in response to your email of February 3, 2023, wherein you requested our views on whether income earned by a Canadian-controlled private corporation (the “Corporation”) from selling electricity generated from solar panels would be considered active business income (“ABI”) eligible for the small business deduction (“SBD”) in subsection 125(1) of the Income Tax Act (“Act”). ...

11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident Unedited CRA Tags 126(2.21), 152(4)(b) and (c), 152(4.01), 152(6)(f.1) Principal Issues: Does subparagraph 152(4)(a)(ii) of the Act allow a taxpayer to file a waiver for an emigration year for the purpose of keeping the taxation year open indefinitely to allow the taxpayer to claim a foreign tax credit under subsection 126(2.21) beyond the statutory limits imposed under paragraph 152(4)(b)? ... Agarwal, CPA, CMA, MBA October 11, 2017 Dear XXXXXXXXXX: Re: Foreign tax credit – former resident This letter is in response to your emails dated July 4, 2016 and August 4, 2016, in which you seek clarification regarding the period within which the Minister may assess or reassess a taxpayer’s return of income with respect to a claim for a foreign tax credit under subsection 126(2.21) of the Income Tax Act (“Act”). ...

For this purpose, an annuitant of an RRSP and the RRSP itself are considered to be related persons, (b)       is or is related to a member of a partnership that controls the corporation in any manner, (c)       is or is related to a beneficiary under a trust that controls the corporation in any manner, (d)       is or is related to an employee of the corporation where the employees control the corporation, except where the corporation is controlled by one person or a related group of persons, or (e)       does not deal at arm's length with the corporation. ... A class of shares of the capital stock of 24(1) shall be qualified for distribution to the public. 2.        Where the shares of the class referred to in 1 above are equity shares, there shall be no fewer than 150 persons, other than insiders of 24(1), each of whom holds          (a)    at least one block of shares of that class, and          (b)    shares of that class having an aggregate fair market value of at least $500. 3.        ...

Branch Level Interest Tax & Foreign Tax Credit Unedited CRA Tags 18(1)(a), 126, 126(7) business-income tax, 126(7)(c)   Corporate Management Tax Conference Foreign Tax Credit- U.S. ... Department's Position (a)      No. The BLIT is not an "income or profits tax" for the purposes of paragraphs 126(7)(a) or (c) of the Act for the simple reason that the BLIT is not imposed on the branch's income or profits. (b)      Yes. The BLIT is considered to be a deductible expense under paragraph 18(1)(a) of the Act on the basis that it is an outlay incurred for the purposes of gaining or producing business income. ...

À moins d’indication contraire, toute référence à un article de loi ou à une de ses composantes dans le présent document constitue une référence à un article de la Loi de l’impôt sur le revenu (footnote 2) (ci-après la « Loi ») ou à une de ses composantes. ... Report des crédits inutilisés – ce type de CFM prévoit le report prospectif des crédits inutilisés sur une période maximale de 12 mois 2. Report des frais médicaux – ce type de CFM prévoit le report prospectif des frais médicaux admissibles non remboursés sur une période maximale de 12 mois 3. ...