Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

. … Since Schedule I does not address this situation, the Payment is subject to subsection 106(1). ...

Had the Fund now held Opco directly, this would have been accomplished by incorporating a subsidiary (“MFC”), distributing relatively modest shareholdings in MFC to its unitholders sufficient to qualify MFC as a mutual fund corporation, amalgamating MFC and Opco so that Amalco MFC also qualifies as a mutual fund corporation, and then instigating the merger of Amalco MFC into the Fund under s. 132.2 – so that the former assets of Opco are now held directly by a REIT (the Fund). ...

2017 Ruling 2017-0699201R3- Cross-border Butterfly-- summary under Paragraph 212.1(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(1.1)- Paragraph 212.1(1.1)(b) application on 4-party exchange CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. ...

. … Whether the Minister agrees to the request would depend on the particular facts of the situation. ...

CRA indicated that the exclusion in s. 112(3.32) from the application of s. 112(3.2)(b) should apply where an estate has received an s. 84(3) deemed dividend on a redemption, it designates that dividend, distributes it to the spousal trust, and the spousal trust in turn designates and pays it to the individual beneficiary – so that the taxable dividend does not reduce the loss. ...

Content Provider which relates to the streaming of the digital content to Canco’s subscribers to the extent that the right in or to the use of the digital content is being used or reproduced in Canada” – except that: Canadian withholding tax can still apply, should the right in or to the use of the digital content be partly used or reproduced in Canada prior to being streamed to these foreign subscribers for viewing outside of Canada (but only to the extent of the payment that is related to the use or reproduction in Canada) or if it was being streamed in Canada. ...

Would this dividend be characterized as income that is derived directly or indirectly from a related business for s. 120.4 purposes – and would the answer change if the dividend was paid before 2018? ...

X's shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends … notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...

However, CRA then stated: By virtue of subparagraph 120.4(1.1)(c)(ii), the amount that is Jeanne's income from property is deemed to be an excluded amount to the extent that the amount would have been an excluded amount in respect of an individual- Jean – who was, immediately before his death, Jeanne's spouse or common-law partner, if the amount were included in computing Jean's income for his last taxation year. ...

(c)(ii)(D) of the definition of "split income" depending on the level of involvement of Julien, but went on to indicate that even if this were the case, the exclusion in s. 120.4(1.1)(c)(ii) would appear to apply: By virtue of subparagraph 120.4(1.1)(c)(ii), the amount that is Jocelyne's income from property is deemed to be an excluded amount to the extent that the amount would have been an excluded amount in respect of an individual- Joseph – who was, immediately before his death, Jocelyne's spouse or common-law partner, if the amount were included in computing Joseph's income for his last taxation year. ...