Search - 三河市 市委书记 现任

7 September 1990 Administrative Letter 901756 F- Surplus Strip Unedited CRA Tags 84.1, 112, 245(2) 19(1) 901756   M.P. ... As indicated at pages 50 to 53 of the Technical Notes to a Bill Amending the Income Tax Act and Related Statutes issued by the Honourable Michael Wilson, Minister of Finance, in November 1985,      "Section 84.1 of the Act is an anti-avoidance rule to prevent the removal of taxable corporate surpluses as a tax-free return of capital where there is a non-arm's length transfer of shares by an individual resident in Canada to a corporation....       ... New paragraph 84.1(1)(b) treats the purchaser corporation as having paid a dividend to the transferor where the aggregate of the amount of the increase in the legal paid-up capital of its shares arising as a result of the share transfer and the fair market value of the non-share consideration given by it for the transferred shares  exceeds the total of      (a)  the greater of the adjusted cost base, as modified under new paragraph 84.1(2) (a) or (a.1), to the transferor of the transferred shares and the paid-up capital of the transferred shares, and       (b)  the total paid-up capital reductions required by paragraph 84.1(1)(a) to be made by the purchaser corporation.       ...

17 July 1991 Administrative Letter 911293 F- Date of Entitlement to Indian Status Unedited CRA Tags ITR 1102(5), 1100(1)(b)   911293   W. ... Guglich   (613) 957-2102 July 10, 1991 Dear Sirs: Re:      Date of Entitlement to Indian Status pursuant to Bill C-31 In your letter of April 19, 1991, which was addressed to the Department of Finance, you request confirmation of our Department's position regarding the date of an individual's entitlement to Indian status pursuant to Bill C-31. ...

7 January 1992 Administrative Letter 9134186 F- Maintenance Payments Adult Child Third Parties Unedited CRA Tags 60(b), 60(c), 60.1(1)   913418   R.B. Day   (613) 957-2136 January 7, 1992 K. BeriniAppeals BranchBusiness and GeneralAppeals & Referrals Division       Division 19(1)- Maintenance Payments We are writing in reply to your memorandum of December 9, 1991, wherein you requested our opinion as to whether or not payments made by the above-noted taxpayer to his adult daughter could be considered to be maintenance payments for purposes of paragraphs 60(b), 60(c) and subsection 60.1(1). ... 2.      Do payments made to a child subsequent to reaching the age of majority qualify as maintenance payments considering the requirements of 24(1) law? ...

2 July 1991 Administrative Letter 911596 F- "Remission Order" Regarding Moving Expenses Unedited CRA Tags n/a   911596                                         R.B. Day                                         (613) 957-2136 July 2, l99l      19(1) We are writing in reply to your letter of June 6, l99l, wherein you requested background information on the "remission order" regarding moving expenses, that was reported in a recent article in the Toronto Star newspaper. ...

Hence, based on the express wording of the subsection, we are of the view that the loss-reduction rule contained therein applies (assuming that the exception provided by paragraphs 112(4)(a) and (b) is not available) even where: (a)      the shares in question are shares of a corporation not resident in Canada; and (b)     the dividend received on such shares is not deductible. ... The portion of subsection 4(4) which is relevant to this analysis is:      ... no provision of this Part shall be read or construed to require the inclusion... in computing the income of a taxpayer for a taxation year or his income or loss for a taxation year from a particular source... of any amount to the extent that amount has been included... in computing such income or loss under, in accordance with or by virtue of any other provision of this Part.       ... Accordingly, paragraph 12(1)(k) and subsection 112(4) may both apply, without offending subsection 4(4). 3.      ...

2 February 1994 Administrative Letter 9337336 F- Indians- Employment Agency Unedited CRA Tags 5(1), 9(1), 81(1)(a) February 2, 1994 Source Deductions Division     Head OfficeDistrict Office and Taxation Centre      Rulings DirectorateSupport Services      957-8953 Attention:  R. ... Albert for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch cc.       ... Owen, Client Services Directorate     David Cowie, Vancouver District Office ...

Dath DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch c.c.      Technical Publications Division      John Oulton, Acting Director ...

14 May 1990 Administrative Letter 900566 F- Deductibility of Employer Contributions under an RCA Unedited CRA Tags 12(1)(n.3), 20(1)(r), 207.5(1) RCA trust 24(1) File No. 900566   Maureen Shea-DesRosierss   (613) 957-8953 19(1) May 14, 1990 Dear Sirs: Re:  Deductibility of Employer Contributions under a Retirement Compensation Arrangement ("RCA") This is in reply to your letter of April 25, 1990 concerning the above-mentioned subject. You describe the following RCA plan:-      both employees and employer are beneficiaries;-      amounts are to be paid out by the custodian as follows:-      employees would receive 50% of the employer's contribution plus  an amount equal to the 100% of the RCA's income for tax purposes.-      the employer would receive 50% of its contributions.  ...

Our Comments 1.     The ruling set out in 29 continues to represent the Department's views on amalgamation of NPO's. 2.      ... In this respect, the Department has taken the view that if the letters patent, trust documentation or by-laws of an entity indicate that anything more than the return of capital or taxable capital gains as provided by section 149(2) of the Act may be made available to members by way of dividend or otherwise, whether on winding-up or otherwise, such an entity will not receive tax-exempt treatment.       ... Where, however, the dividends are paid by a related or associated NPO the comments in 4 above apply. 6.      ...

THE REGULATIONS Let us first look at the relevant provisions of the Regulations. 1.      ... (See the meaning of "salary or wages" in subsection 248(1) of the Act) 4.      ... " 5.      We would like to draw your attention to an important distinction. ...