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

. … HBP participants who withdraw over more than one year will generally be contacted by the CRA to confirm details of their participation. ...

. … Thus, as soon as a transaction creates legal impacts in a taxpayer's taxation year that are not otherwise statute-barred, the resulting tax consequences may be determined by the Minister. ...

. … The income of the Trust for the XXXXXXXXXX taxation year would be computed under Canadian rules pursuant to section 250.1 and would include the $XXXXXXXXXX dividends received. ...

After noting that such policy did not apply to cash equivalent gifts and awards, such as where the employee receives reward points, which are accumulated and can be redeemed for a choice of goods, CRA stated that there could be “arguments that the points may not constitute a cash or cash equivalent award … since the points cannot be converted into cash and the number of goods that the employee can acquire, in exchange for the accumulated points, is very limited.” ...

. … [I]f the trust continues to exist after deregistration and the shares of the cooperative are not transferred to the annuitant in the year of deregistration or are transferred in a year subsequent to the year in which subsection 146(12) applies, we are of the view that no withholding tax is required under the application of the provisions of the Act and Regulations since no payment is made on deregistration and in the year of deregistration. ...

. … [I]n 2002, the partner did not elect to add back income from that business pursuant to subsection 34.1(2). ...

. … [U]nlike paragraph 251(5)(b), the definition of term preferred share does not contain the exception that applies where one or more of the rights referred to in that provision cannot be exercised at that time because the exercise of the rights in question depends on the death, bankruptcy or permanent disability of an individual. ...

. … Where an employee elects to receive the amount of the retiring allowance in instalments, it is our view that the instalments will be taxable in the year they are received. ...

. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

3 November 2004 Internal T.I. 2004-0083791I7 F- Paragraphe 44.1(2)-- summary under Subsection 44.1(8) Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(8) pre-condition of carrying on business not satisfied / general overview provided A newly-formed corporation used its cash share subscription proceeds almost entirely to purchase a piece of land for which, to date, a required zoning change has not yet been obtained. ...