Search - 制暴无限杀机 下载

CRA indicated that, under ETA s. 182, Aco is deemed to have collected the GST/HST as part of the liquidated damages amount, which is deemed to be consideration for a taxable supply by it, and Bco would be deemed to have paid that GST/HST (notwithstanding that Cco is the actual payer) – so that Bco (not, Cco) would be able to claim an ITC for the deemed GST/HST payment if the usual conditions in s. 169 were satisfied. ...

Summary of 22 December 2022 Internal T.I. 2020-0856411I7 F under s. 125.7(1) – eligible remuneration. ...

Summaries of 7 April 2022 CBA Roundtable, Q.3 under ETA s. 191(3) and s. 123(1) – real property. ...

., the expenditure was in respect of “the acquisition of property that has been used … for any purpose whatever before it was acquired.” ...

CRA indicated that in this regard it would apply the principle in IT-433R, subpara. 3(a) that the meaning of the term "received" is broad enough to consider a taxpayer to have received an amount where it “was received by a person authorized to receive it on behalf of the taxpayer” – and further stated that “a person entitled to receive an amount on behalf of a taxpayer for CEWS purposes may include a person who is entitled to receive the amount for a taxpayer by inter alia an agreement or by statute.” ...

Summary of 3 August 2022 GST/HST Ruling 229371 under ETA s. 123(1) – recipient. ...

Summaries of 26 January 2023 External T.I. 2021-0887661E5 under s. 125(7) – specified corporate income- (a)(i) and s. 125(5.1)(a). ...

Summary of 1 February 2023 External T.I. 2022-0945221E5 under s. 149.1(1) – qualified disbursement. ...

CRA indicated that, very generally, a beneficiary of a trust is a person, other than the protector, who has the right to compel the trustee to properly enforce the terms of the trust, regardless of whether that person’s right to the income or capital of the trust is immediate, future, contingent, absolute or conditional on the exercise of the discretion of any person – so that, accordingly, a beneficiary in the ordinary sense would include a beneficiary whose interest is contingent. ...

In this regard, Headquarters observed that inter alia Clibetre and Orlando indicated that “where requested changes to elements of the taxpayer’s return of income are denied, and there is no change to the tax payable previously assessed … there has been no ‘reassessment’ of tax by the Minister,” and such denial is instead “simply a notification that a reassessment has not been done” (“even if the notification is titled a ‘Notice of Reassessment’.”) ...