Search - 制暴无限杀机 下载

26 February 2018- 11:24pm CRA indicates that the deemed U.S. income inclusion from an IRA on renouncing U.S. citizenship or relinquishing a green card also is recognized for ITA purposes Email this Content Where a U.S. long-term resident relinquishes her green card (or a U.S. citizen renounced citizenship) after having become a Canadian resident, there would be a deemed taxable distribution to her of the amount in her IRA for Code purposes – which by virtue of ss. 56(1)(a)(i)(C.1) and 56(12) would be deemed to be included in her income at that time for ITA purposes as well. ...

Summaries of 7 February 2018 External T.I. 2016-0637221E5 under s. 66.2(5) – Canadian development expense and s. 85(1)(a). ...

The proposed transactions entailed the s. 85(1) transfer by him to a Newco of his Opco shares for notes in an amount close to the transferred shares’ hard ACB and preferred shares as to the balance – followed by an amalgamation (or wind-up) of the Opcos over a year later and gradual repayment of the notes on a redacted timetable. ...

CRA stated: Although the [children’s programs] are enriched by recreational and athletic activities … the primary purpose of the programs is to provide care and supervision to children 14 years of age and under. ...

Summaries of 13 December 2017 Interpretation 187306 under ETA s. 225.1(2) – B and s. 169(1). ...

Summary of 16 May 2018 IFA Roundtable, Q.1 under Treaties – Income Tax Conventions- Art. 29. ...

Summary of 16 May 2018 IFA Roundtable, Q.2 under Treaties – MLI- Art. 7(1). ...

Accordingly, its failure to meet statutory deadlines will carry the associated statutory penalties – but CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...

Where it is not, however, it should still be possible to file the T1134 on time but with some missing information – but bearing in mind that penalties could thereby apply, subject to relief in the reasonable efforts exception of s. 162(5)(a), or the due diligence exception of s. 233.5(c.2). ...

19 June 2018- 11:55pm CRA accommodates backdating a GST/HST registration by over six years in order to claim ITCs Email this Content A not-for-profit corporation registered for GST/HST purposes effective March 18, 2016, then got this registration backdated somewhat to January 1, 2016 – and then subsequently filed returns for the previous six years (2010 through 2015) and requested that its registration be further backdated to April 1, 2010 in order that it could claim input tax credits for tax paid since April 1, 2010. ...