Search - 制暴无限杀机 下载

A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

Regarding the mechanics of the loss shift, the interest on the loan by Lossco to ACo, as well as the dividends on the corresponding preferred shares held by Aco in a Newco subsidiary of Lossco, are allowed to accumulate until the time of unwinding the structure, at which point Lossco makes a cash capital contribution to Newco to fund the payment of such dividend arrears whose payment, in turn, funds the payment of the interest owing by Aco – but the loss shifting transactions otherwise are unwound on a cashless basis. ...

Summary of 21 August 2020 Internal T.I. 2019-0834911I7 under s. 110.2(1) – qualifying amount. ...

30 December 2020- 11:37pm CRA finds that sponsorship of a PSB’s staged production was not subject to GST/HST Email this Content ETA s. 135 deem a supply by a public sector body (PSB) of a service, or a licence of copyright, a trade-mark, trade-name or other similar property to a “sponsor” for exclusive use by the sponsor in publicizing the sponsor’s business, to not be a supply – except that this rule is stated not to apply where the consideration for this supply by the PSB to the sponsor is “primarily” for radio, TV, newspaper, or magazine advertising. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to exceptions including that in s. 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person while a non-resident in Canada – as to which there would be full taxability under s. 56(1)(a)(i) regardless of non-deductibility of contributions to the plan or a foreign tax exemption for the pension benefits. ...

Summary of 23 June 2020 External T.I. 2020-0848441E5 F under s. 149(1)(c) and s. 125.7(1) – eligible entity. ...

Summary of 2020 Ruling 2018-0772291R3 F under s. 55(1) – distribution. ...

Tax Topics (Wolters Kluwer), No. 2556, 2 March 2021, p. 1 under General Concepts – Ownership. ...

Instead, “the assigned revenue described in paragraph 125.7(4.2)(a) … refers to the qualifying revenue of the seller for the entire prior reference period that is reasonably attributable to the acquired assets.” ...

Relaxing CRA's procedures and any administrative policy in that regard would require a thorough review …. ...