Search - 制暴无限杀机 下载

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Unedited CRA Tags Article XXX(3) of the Canada-Barbados Treaty Principal Issues: Under the Insurance Act (Barbados), a Class 2 licence entitles the company to insure third-party risks wherever situated. ... Reasons: See below. 2023 IFA Annual Conference CRA Roundtable Question 4- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ...

15 September 2020 IFA Roundtable Q. 6, 2020-0853561C6- Subsection 212.3(9) & The GAAR Unedited CRA Tags 18(4), 212(2), 212.3(9), 245(2). ... Reasons: See below. 2020 International Fiscal Association Conference CRA Roundtable Question 6 – Subsection 212.3(9) and The GAAR At all relevant times, a non-resident corporation owns all the common shares of a corporation resident in Canada (Canco), which shares are the only issued and outstanding shares of Canco. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10 Unedited CRA Tags 207.6(2) Principal Issues: 1) What factors does the CRA consider in determining whether the RCA deeming rule in subsection 207.6(2) applies to a particular life insurance policy? ... CALU CRA Roundtable – May 2012 Question 10- Deemed RCA Rules Background Subsection 207.6(2) of the Act deems the RCA rules to apply to situations where 1) the employer has a legal obligation to provide benefits that are to be received or enjoyed by any person on, after, or in contemplation of any substantial change in services rendered by the retirement or loss of an office or employment of a taxpayer; 2) the employer acquires an interest in a life insurance policy; and 3) such insurance policy “may reasonably be considered to be acquired to fund, in whole or in part,” the benefits. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician Principal Issues: Question 7 of the 2019 Step Conference. 1. ... Reasons: Our previous position. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 7. ...

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA Unedited CRA Tags 89(1) "capital dividend account", 148(9) "disposition" Principal Issues: Whether or not a payment under a particular life insurance policy would be considered proceeds of a life insurance policy in consequence of death for purposes of the definition of “capital dividend account” in subsection 89(1) of the Act. ... Reasons: The determination is a question of fact. 2020 CALU CRA Roundtable – July 2020 Question 2- Return of premiums on death- Capital Dividend Account Background With respect to the calculation of a corporation’s capital dividend account, when proceeds of a life insurance policy are received by the corporation, paragraph (d) of the definition of “capital dividend account” in subsection 89(1) of the Act provides for, in part, the inclusion of the following [subject to reductions listed in subparagraphs (d)(iii) to (d)(vi) of that definition] “all amounts each of which is the proceeds of a life insurance policy… of which the corporation was… a beneficiary… received by the corporation… in consequence of the death of any person” [emphasis added] The term “proceeds of a life insurance policy” is not defined in the Act. ...

7 May 2024 CALU Roundtable Q. 4, 2024-1007061C6- Shared Ownership & Charitable Gift Unedited CRA Tags 118.1, 148, 248 Principal Issues: Can the CRA provide an update on its views with respect to shared-ownership arrangements in the context of charitable giving? ... CALU Roundtable- May 2024 Question 4 – Shared Ownership Arrangements and Charitable Gifting Background There are circumstances where two parties may wish to jointly own and benefit from a life insurance policy. ...

4 June 2024 STEP Roundtable Q. 10, 2024-1010241C6- Update on trust / estate issues Unedited CRA Tags 104(6)(b); 104(13); 104(24) and 105(1) Principal Issues: Can CRA provide an update on any recent trust or estate issues that may be of interest to the STEP audience? ... Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 10. ...

30 October 2012 Ontario CTF Roundtable Q. 8, 2012-0462841C6- Ontario CTF – Q8 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate at the Prairie conference and the BC conference Ontario Tax Conference October 30, 2012 Question 8 – Residency of a Trust for Tax Purposes (a) CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

8 May 2012 Roundtable, 2012-0435641C6- CALU CRA Roundtable Question 6 – May 2012 Unedited CRA Tags 104(1), 89(1)(d) Principal Issues: Whether a corporation can be considered to have received insurance proceeds for the purpose of paragraph (d) in the definition of "capital dividend account" in subsection 89(1)? ... Question 6 – Use of Bare Trustee and CDA Background It is not uncommon for shareholders of a corporation to use a buy-sell arrangement which requires the corporation to acquire insurance to fund share purchase obligations under the arrangement. ...

16 June 2014 STEP Roundtable, 2014-0522971C6- STEP CRA Roundtable – June 2014- Question 3 CRA Tags 93.3 Principal Issues: How are equity interests in foreign corporations without share capital divided into deemed classes of capital stock? ... Reasons: Text of proposed 93.3 STEP CRA Roundtable – June 2014 QUESTION 3. ...