Search - 制暴无限杀机 下载

Where there is intended reliance on the moneylending business exception, there will need to be a calculation of the percentage representing the moneylending to entities within the group, during all of the time in which the loan is outstanding – which could create difficulties if inter alia loan balances vary on a daily basis. This amendment applies not only to loans made after 2022, but also to any portion of a particular loan made before 2023 that remains outstanding on January 1, 2023 as if that portion were a separate loan that was made on January 1, 2023 – so that taxpayers may be required to take remedial action in respect of pre-existing upstream loans. ...

Canco, which has business income of $1,100 after deducting interest expense of $1,400, also has a wholly-owned CFA that has income from property of $400 after deducting interest expense of $600, and pays no tax – so that Canco’s income including FAPI is $1,500. ... If the CFA had incurred a foreign accrual property loss (FAPL) instead of FAPI, the RAIFE of the CFA would nonetheless be included in the IFE of Canco – even though that FAPL might never be deducted in computing Canco’s income. ...

28 June 2023- 11:45pm CRA illustrates the resident portion rules for a s. 94 trust that inter alia has lent to a resident beneficiary or earns FAPI Email this Content Regarding where a loan is made by a non-resident trust (which has made a valid (resident portion) election under s. 94(3)(f)) to a Canadian resident beneficiary, CRA noted that s. 94(2)(g)(iv) provides that the loan to the beneficiary involves the acquisition by the trust of the debt which entails a deemed transfer by the debtor – so that, here, there is a deemed transfer of property from the beneficiary to the trust. ... Summary of 20 June 2023 STEP Roundtable, Q.7 under s. 94(1) – resident portion. ...

In a March 12 update to its webpage on bare trust reporting, CRA stated: As some bare trusts may be uncertain about the new requirements, the CRA is adopting an education-first approach to compliance and providing relief to bare trusts by waiving the penalty payable under subsection 162(7) … for the 2023 tax year in situations where the T3 Return and Schedule 15 are filed after the filing deadline for reasons other than gross negligence. … While the Act also includes a gross negligence penalty under subsection 163(5), as part of the CRA’s education-first approach, the CRA will only apply this penalty in the most egregious cases where a bare trust fails to file. ...

…Article 18, paragraph 2 … does not provide a specific timeline for making such a request. Further, the Canada-Italy Treaty does not have any other provisions extending the timeframe to a request a refund of tax in respect of taxation that is not in accordance with the provisions of the Canada-Italy Treaty …. ...

Before finding that the taxpayer could not recognize an expense as the rewards were earned (as an expense had not yet been “incurred”), and that the applicable deductions were deferred until the points were redeemed, CRA stated: [T]he courts have held that an expense will not be considered to have been incurred unless the taxpayer has an obligation to pay money to someone … [and] that a legal obligation to pay under contract does not exist until all contractual preconditions to which the payment relates are fulfilled. ... Summary of 25 October 2023 External T.I. 2022-0927891E5 under s. 18(1)(a) – incurring of expense. ...

These are additions to our set of 2,904 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2001-09-28 13 September 2001 External T.I. 2001-0097675 F- COUT INDIQUE REVENUS A RECEVOIR Income Tax Act- Section 248- Subsection 248(1)- Cost Amount- Paragraph (b) cost amount of shares not increased by dividend receivable, and of loan, not increased by accrued interest 30 August 2001 External T.I. 2001-0093645 F- FRAIS IMPUTE A UN REER LORS D'UN RETRAIT Income Tax Act- Section 146- Subsection 146(8) no annuitant benefit where RRSP bears an admin fee on a withdrawal 23 August 2001 External T.I. 2001-0095015 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance retiring allowance can be received in instalments and well in advance of planned termination date 18 September 2001 External T.I. 2001-0095265 F- TAXE SUR LE CAPITAL Income Tax Act- Section 181.2- Subsection 181.2(3)- Paragraph 181.2(3)(c) outstanding cheques are not loans or advances, but they reduce the debts of which they are repayment only to the extent reflected in the balance sheet General Concepts- Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited 17 August 2001 External T.I. 2001-0095645 F- PRET HYPOTHECAIRE INTERETS Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) administratively splitting a mortgage loan into 2 components does not allow the principal repayments to be allocated first to repayment of the loan’s ineligible portion 29 August 2001 External T.I. 2001-0097485 F- DEDUCTION DE FRAIS DE SURVEILLANCE Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(bb) supervisory fees paid to intermediary between portfolio manager and taxpayer were non-deductible ...

In the case of the advertising service, CRA simply noted, without more, that pursuant to ETA s. 142(1)(g), a “supply of a service is deemed to be made in Canada where the service is, or is to be, performed in whole or in part in Canada” – perhaps recognizing that the non-resident might not be regarded as “performing” any services in Canada through its website. On the other hand, regarding any supply of copyright or other intangible personal property (IPP), CRA noted that s.142(1)(c) provides that a supply of IPP is deemed to be made in Canada if the property may be used in whole or in part in Canada, and stated that the “expression ‘may be used’ is interpreted to mean ‘allowed to be used’ – so that “a supply of IPP could be considered to be made in Canada even if it is not actually used in Canada.” ...

These are additions to our set of 2,916 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2001-09-28 3 May 2001 External T.I. 2001-0069535 F- DEPENSE D'INTERET REGLES D'ATTRIBUTION Income Tax Act- Section 74.5- Subsection 74.5(11) potential application of s. 74.5(11) to leveraged s. 73(1) property transfer to spouse 11 October 2001 Internal T.I. 2001-0079197 F- pension alimentaire Income Tax Act- Section 56.1- Subsection 56.1(4)- Commencement Day- Paragraph (b)- Subparagraph (b)(ii) suspension of support did not trigger a commencement day Income Tax Act- Section 56.1- Subsection 56.1(3) post-May 1997 temporary custody order triggered a commencement day 8 October 2001 Internal T.I. 2001-0086177 F- FRAIS DE SCOLARITE Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(a)- Subparagraph 118.5(1)(a)(ii.2)- Clause 118.5(1)(a)(ii.2)(B) English instruction did not qualify as occupational development under s. 118.5(1)(a)(ii.2) 16 August 2001 Internal T.I. 2001-0079317 F- RESIDENCE PRINCIPALE DEMI-HECTARE Income Tax Act- Section 54- Principal Residence- Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use 3 May 2001 Internal T.I. 2001-0081837 F- BILLET CONVERTIBLES PRINCIPAL 2001-0081837 F and 2000-0046367 F are similar. ...

Preliminarily to a proposed butterfly split-up of DC between TC1 and TC2, the note owing to the estate, and the DC preferred shares, would be distributed on a 50-50 basis under s. 107(2) to the two testamentary trusts, from them on a s. 107(2) rollover basis to the two respective children, and by each of them to her or his TC on a s. 85(1) rollover basis – and similarly, the DC common shares would be distributed on a s. 107(2) rollover basis by the Trust to the two children, and by them on a s. 85(1) rollover basis to their respective TCs. ... Summary of 2023 Ruling 2022-0957491R3 F under s. 55(1) – distribution. ...