Search - 制暴无限杀机 下载

In finding that this was not the case, the Directorate stated: [S]ince the SAD Investors are a substantially different group of investors than the SBD Investors … it could not reasonably be considered that the SAD Investors were paid the Redemption Premium “in respect of the substitution of the [SAD]” since it was the SBD Investors, and not the SAD Investors, who provided a substitute debt for the SAD. ...

However, CRA ruled that Investor is not making any taxable supply in exchange for the royalty payments when Corporation 1 makes the subsequent royalty payments – so that Investor would not be entitled to claim input tax credits for the GST/HST paid or payable on related inputs. ...

9 January 2018- 8:16am CRA indicates that a bad debt credit cannot be claimed for uncollectible GST/HST assessed on audit Email this Content ETA s. 231(1.1) provides that a supplier cannot claim a bad debt deduction unless “the tax collectible in respect of the supply is included in determining the amount of net tax reported in the reporting entity’s return … for the reporting period in which the tax became collectible.” ...

V, Pt VI, s. 18 and General Concepts – Agency. ...

Summary of 2017 Ruling 2017-0687061R3 under s. 248(1) – disposition. ...

Summary of Kevyn Nightingale and John Sorensen, "Backdating of Dividends," Tax Topics (Wolters Kluwer), No. 2392, January 11, 2018, p. 1 under General Concepts – Effective Date. ...

This is similar to a less heavily redacted 2014 ruling on an Irish contractual fund (2013-0496831R3 – see also 2009-0345011R3 and 2006-0199741R3), whose description also looked somewhat similar to a unit trust, and was ruled upon to be a co-ownership arrangement. ...

Respecting where two unrelated individuals each held exactly 50% of the (voting common) shares of the employer, CRA noted that under Duha, “the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement” (USA), so that either individual could have de jure control and be related to the employer under s. 251(2)(b)(i). ...

., because CRA applied s. 67 to deny the deductibility to the first CCPC of fees charged to it by the second CCPC – see 2012-0440071E5). ...

CRA confirmed that such employees are not permitted an s. 20(11) or (12) deduction for the foreign taxes paid on such income in excess of a 15% rate because “unlike paragraph 144(8.1)(b) … there is no provision of the Act which deems any portion of the foreign NBIT paid by an EPSP to have been paid by an employee beneficiary for the purposes of subsection 20(11) or 20(12).” ...