Search - 制暴无限杀机 下载

Unedited CRA Tags 112(2.1), 112(1)                Janvier 1991   BUREAU PRINCIPAL                        BUREAU PRINCIPAL Direction générale des                  Direction des décisions   appels                                Division des services Division des appels et                    bilingues   des renvois                           P. ... LES FAITS-      Société d'investissement Desjardins (ci-après SID) est contrôlée par les Fédérations des caisses populaires d'économie Desjardins.-      SID est une "institution financière désignée" aux fins du paragraphe 112(2.1) de la Loi.-      La SID exploite une entreprise de capital de risque.  ... COMMENTAIRES 1.        SID contrôlait SICO, elle a donc pu dans une certaine mesure, orchestrer les événements.  ...

The facts can be summarized as follows: (i)      (ii)     24(1) (iii) (iv)      24(1) The court held that Capitol was not carrying on business in Canada and commented that it would have concluded that Capitol did not have a permanent establishment in Canada in 1976.  ... The Commissioners commented as follows:      "On the closure (of the branches) the policies were transferred for administration to the British division.  Any work connected with them- for example, calculation of annual bonuses, correspondence and payment of benefits- is dealt with in the United Kingdom and nowhere else.       ...

27 September 1989 Ministerial Letter 89M09618 F- Refund to Employee Unedited CRA Tags n/a   September 27, 1989 Mr. Keith Hillier Provincial and International Acting Director Relations Division Non-Resident Taxation Division Legislative and   Intergovernmental   Affairs Branch   E.E. Campbell      (613) 957-2067 19(1) In 1988 we brought to your attention a query form 19(1) concerning the above noted employee.  19(1) was concerned over the refund which he received.  ...

13 July 1990 Ministerial Letter 32988 F- Deductibility of Medical Expenses in respect of Special Schooling Unedited CRA Tags 118.2 19(1) 3-2988   J. ... Our Comments Paragraph 118.2(2)(e) of the Act provides that the amounts paid must be      "... for the care, or the care and training, at a school, institution or other place of the patient, who has been certified by an appropriately qualified person to be a person who, by reason of a physical or mental handicap, requires the equipment, facilities or personnel specially provided by that school, institution or other place for the care, or the care and training, of individuals suffering from the handicap suffered by the patient;". ... Your deposit of $325.00 will be returned under separate cover. for Director Business and General DivisionRulings DirectorateLegislative and Intergovernmental  Affairs Branch Attachment- IT-519 c.c.       ...

For 1995 and 1996, the professional income as a lawyer, was $ 100,000 for each year and the individual received in 1996 $ 15,000 as a judge. The RRSP deduction limit for this individual for 1996 and 1997 will be as follows assuming that there is no unused RRSP deduction room at the end of each taxation year. 1996 1997 Lesser of: (a) RRSP dollar limit for the year and $ 13,500 $ 13,500 (b) 18% of the earned income for the previous year 18,000 20,700 less: The prescribed amount for the year nil 1,700 (1) RRSP deduction limit $ 13,500 $ 11,800 (1) lesser of (a) 18% of $ 15,000 minus $ 1,000 (b) $ 13,500 EXAMPLE II The following example is based on the Notice of Ways and Means Motion of December 1996 and the draft amendments to the Income Tax Regulations of February 1997. ... The RRSP deduction limit for this individual for 1996 and 1997 will be as follows assuming that there is no unused RRSP deduction room at the end of each taxation year. 1996 1997 Lesser of: (a) RRSP dollar limit for the year and $ 13,500 $ 13,500 (b) 18% of the earned income for the previous year 27,000 27,000 less: The prescribed amount for the year 14,500 (1) 13,500 (2) RRSP deduction limit nil nil (1) lesser of (a) 18% of $ 150,000 (b) $ 15 500 less $1,000 (2) lesser of (a) 18% of $ 150,000 minus $ 1,000 (b) $ 13,500 ...

However, the comments under all of these paragraphs are somewhat incomplete since the key phrase "in respect of the production or reproduction" in subparagraph 212(1)(d)(vi) is missing in each of these paragraphs.       ... (iii)     payments made by a person resident in Canada to a           non-resident under a license agreement whereby the          non-resident owner of a computer program grants rights to such a person to produce or reproduce the program in Canada for distribution to other persons.      The payments described in (i) and (ii) above are subject to Part XIII tax by virtue of subparagraph 212(1)(d)(i) of the Act and they do not fall under the exemption provided under subparagraph 212(1)(d)(vi) of the Act.       ...

25 May 1992 Ministerial Letter 9212388 F- Taxable Benefit-Interest Free Loan To Beneficiaries Unedited CRA Tags 105(1)     # 5-921238   John Chan May 25, 1992 ISSUE SHEET Question 40- Benefit on Interest-Free Loans to Beneficiaries (1991 Canadian Tax Foundation Roundtable) Issue The question asked Revenue Canada to confirm that it will not assess a taxable benefit under subsection 105(1) where a trust makes an interest-free loan to a beneficiary. ... That Revenue Canada has adopted the position in the Cooper case was published in the 1991 and 1990 CTF Roundtables and in an external opinion to 24(1) dated July 19, 1990 (File # 901275).   See also Appeals Decision # 89-16 dated March 22, 1989. ...

(a)  It is our opinion that section 54.2 of the Act does not deem the shares to be capital property of the LP because the LP is not a person under the Act.       ... "      (b)  The issue of whether a particular transaction is on income or capital account will depend on all the circumstances of each case.  ... " The profit derived therefrom, could be taxed as ordinary income of that person.       ...

22 June 1989 Ministerial Letter 73818 F- Private Health Services Plan Unedited CRA Tags 118.2(2), 248(1) private health services plan   June 22, 1989 Source Deductions Division Small business and L.P. Mancino, Director General Division   A. Humenuk   957-2135   File No. 7-3818   Your File      HAK-9092-1     RE-1347 Subject:  Private Health Services Plan We are responding to your memorandum of April 12, 1989,concerning the Treasury Board' Isolated Post Directive (IPD) as outlined in Volume 25 Chapter 1 of the Personnel Management Manual.  ...

18 September 1990 Ministerial Letter EACC9708 F- Omi Gupta- Adverse Decision of Tax Court Unedited CRA Tags n/a   September 18, 1990 Appeals and Referral Division B. Buetow   Technical Review Section Attention: James E. Nordin Technical Publications   Division   957-9226   EACC9708 Subject:  Omi Gupta Adverse Decision of the Tax Court The taxpayer, a surgeon in Edmonton, reported a capital loss in 1983 on commodity transactions and income losses in 1984 and 1985 on such transactions.  ... BuetowChiefTechnical Review SectionTechnical Publications Division c.c.       ...