Search - 侵犯公民个人信息罪 交易明细 计算条数

" Ruling that the Dealer's Fee received by the Dealer either as a lump-sum payment or as periodic payments for facilitating the initial sale of the […] Shares to the Client, is consideration for an exempt supply of arranging for a financial service under paragraph (l) of the definition of financial service in subsection 123(1). However, if at any time after the initial sale, the Dealer "services" the Client's account in order to earn the Dealer's Fee, or if the fee is paid to a Dealer who did not facilitate the initial sale of the […] Shares, the supply of the services for which the Dealer's Fee is paid may be considered the provision of a taxable supply. ... [T]o "service" a Client's account includes, but is not limited to: regularly contacting the Client after the initial sale to review the status of the account and the appropriateness of the […] Shares held in the account in light of the Client's financial needs and investment objectives (e.g., holding the Client invested in those Shares, performing research and analysis); offer advice by recommending any appropriate change in the account; and provide assistance to the Client by answering any questions the Client may have regarding the […] Shares and on exercising any right or privilege connected to those Shares or to the account ...

CRA ruled that s. 95(2)(a)(i) deemed the income of one of the FA5 Subsidiaries to be active business income, and an addition to its exempt surplus under Reg. 5907(1) – exempt earnings – s. ... Here, FA4 also held distressed debt portfolios of its own, albeit partly through a subsidiary LP – and one of the conditions for the CRA ruling was that LP qualified as a partnership for ITA purposes. ...

CRA ruled that this double transfer of the ForSub1 shares would not result in those shares not qualifying as capital property: For purposes of subsection 85.1(3), provided that the ForSub1 Common Shares constitute capital property to CanSub1 immediately prior to the transfer of the shares by CanSub1 to CanSub2 … the transfer by CanSub1 of the ForSub1 Common Shares to CanSub2 … and the subsequent transfer by CanSub2 of such shares to ForSub2 … will not, in and by themselves, cause such ForSub1 Common Shares not to be capital property of CanSub2. ...

More specifically: Aco establishes a new sister to Bco (Newco) to which Aco does an s. 85(1) drop-down of preferred shares of Bco having a fair market value equaling that of the trademarks; Bco spins-off the trademarks to Newco on a partial rollover basis in consideration for prefs of Newco, thereby using Bco’s net capital losses to effect a ½ step-up of the UCC of the trademarks under s. 13(7)(e)(ii) – and with Newco licensing the trademarks back to Bco for royalties; The prefs in 1 and 2 above are cross-redeemed (with reliance on the s. 55(3)(a) exception to s. 55(2)); Newco is wound-up under s. 88(1); Aco does an s. 85(1) drop-down of the trademarks back to Bco, but choosing an elected amount so as to uses up its net capital losses and to effect a further ½ step-up of the trademarks' UCC under s. 13(7)(e)(ii). ...

2015 Ruling 2014-0527961R3- Deemed dividend under subsection 90(2)-- summary under Subsection 90(2) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(2) € and US$-denominated shares viewed as separate classes underline;">: €/US$ share structure. ... Given the current relative currency values, the paid in capital of the €€ shares on a per share basis is greater than the paid in capital of the US$ shares and, as a result, the €€ shares will be entitled on a per share basis to a larger proportion of the dividend. ...

Position: Yes …. Reasons: The circumstances of this corporation are substantially similar to those in respect of which a favorable ruling was given in … 2015-0577141R3, following the liberal interpretation first taken in … 2000-0004783. ...

After referencing the ss. 6(1) and 7 rules, CRA stated: Based on the facts, the Registration fees that the [Organization] collects from individuals who attend a particular […] conference are consideration for a supply of IPP in respect of which the Canadian rights can only be used in the province in which the […] conference takes place. ...

2004 Ruling 2004-007680-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) // www.bci.ca/ "> www.bci.ca): Non-capital losses of BCI are transferred to its affiliate, Bell Canada, pursuant to transactions under which a subsidiary of Bell Canada ("Bell Subco") borrows up to $17 billion on a day-light loan and uses the borrowed money to subscribe for preferred shares of a newly-incorporated subsidiary of BCI ("BCI Subco"), BCI Subco lends the money on a non-interest bearing basis to BCI, BCI lends the same funds on an interest-bearing basis (1 basis point lower than the dividend rate on the preferred shares) to Bell Subco, which pays off the day-light loan. ...

They each will own ½ of the common shares of the "Project General Partner" of New LP and subscribe for an equal number of LP units. ... See detailed summary under s. 122.1(1) – real estate investment trust. ...

2013 Ruling 2012-0443081R3- Distribution of pre-72 Capital Surplus on Hand-- summary under Personal-Use Property Summary Under Tax Topics- Income Tax Act- Section 54- Personal-Use Property Are non-interest bearing loans, for example to a non-resident corporation or to a non-resident child of a parent, "personal-use property" ("PUP") – so that for example they would not be "specified foreign property" in s. 233.3(1)? ... The Queen, 2011 TCC 47, and in finding that such debt generally would not be PUP, CRA stated: [T]o qualify as PUP under paragraph (a) the property must be owned and actually used primarily for the personal use or enjoyment of the taxpayer or a related person. … A debt would normally only qualify as PUP under paragraph (b), which requires the debt result from the disposition of a property which itself was PUP. ...