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

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement Meaning of "substantial changes in the services" (p. 481) CRA... will consider that there has been a substantial change in services for the purposes of the definition of an RCA when the person retires or is terminated but continues to render different services than the ones formerly rendered to the employer. ...

– Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36-- summary under Paragraph 143.3(5)(b) Summary Under Tax Topics- Income Tax Act- Section 143.3- Subsection 143.3(5)- Paragraph 143.3(5)(b) Excess is of cost over FMV (p. 6) Implicit in the [Finance] technical note statements is the assumption that, for purposes of paragraph 143.3(5)(b), the "amount determined to be an excess" under subsections 143.3(3) and (4) is the amount, if any, by which the expenditure as otherwise determined (as opposed, necessarily, to the FMV of the share) exceeds the FMV of the property transferred or issued to, or the services provided to, the issuer for the share (or interest). ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Income from Property Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Income from Property Cash risked in active business (p.20:24-25) Interest earned by a foreign affiliate on cash/deposits risked in the active business of the foreign affiliate should be treated as income that pertains to or is incident to that active business and therefore should not be included in computing its income from property. ...

., Sweet & Maxwell, 2002-- summary under Subsection 248(20) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(20) Partition at common law (p. 327) Joint tenants and tenants in common have always been able to make a voluntary partition of the land concerned if all agreed; their co-ownership thus comes to an end as a result of each of them becoming sole tenant of the piece of land allotted to him. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subparagraph 93.1(2)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 93.1- Subsection 93.1(2)- Paragraph 93.1(2)(d)- Subparagraph 93.1(2)(d)(i) S. 93.1(2)(d)(i) applies to gross amount of dividend It seems to be a well-established and accepted position that the limitation is meant to apply to the gross amount of the dividend that is taken into account in computing the partnership’s income, without reference to interest or any other expense or deduction taken by the partnership to compute its net income. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) QROC election intended to address unavailability of Reg. 5901(2)(b)(ii) election to partnerships [A]lthough subsections 93.1(1) and (2) are meant to allow a CRIC to access this [FA dividend] regime through partnerships, no pre-acquisition surplus election is available to a partnership that is a shareholder of the distributing FA, even if each of its members is a CRIC or an FA of a CRIC…. ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) S. 20(1)(f) deduction unavailable where debt assumed (unless s. 248(26) available) (p. 18:12) [P]aragraph 20(1)(f) permits a deduction only to the original issuer of the debt. ...

Ken Snider, "Share for Share Exchanges — Subsection 85.1(5) Revisited", International Tax (Wolters Kluwer CCH), No. 114, October 2020, p. 5-- summary under Subsection 85.1(5) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(5) Potential deeming of shares of non-resident to be taxable Canadian property (TCP) (p.5) Where the Exchanged Foreign Shares are taxable Canadian property ("TCP") to the vendor, the Issued Foreign Shares are deemed to be TCP at any time within 60 months after the exchange. ...

Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Not engaged merely by support agreement or arrangement agreement The entering into of a support agreement or an arrangement agreement prior to implementing an acquisition of a Canadian target should not be considered to be the granting of s. 251(5)(b) rights until the shareholders have tendered their shares or approved the transaction (p. 36: 7). ...

Tim Barrett, Andrew Morreale, "Foreign Affiliate Update", 2019 Conference Report (Canadian Tax Foundation), 35: 1 – 53-- summary under Subsection 90(9) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(9) Issues with upstream loan rules Remaining issues with the upstream loan rules include: “Surplus deficits in entities above the lending entity remain problematic, even where there is sufficient net surplus within the chain of affiliates.” ...