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

. … [I]t is the longstanding administrative practice of the CCRA that a subsection 15(1) benefit will not be assessed in respect of a benefit arising from the reinvestment of dividends in additional shares under a DRIP, provided that the amount paid for the additional shares is not less than 95% of their fair market value. ...

. … Where a corporation receives a dividend that is deductible in computing its taxable income and the dividend does not benefit from the safe income exception, the determination of whether the dividend will be recharacterized as a capital gain under subsection 55(2) and the purpose test should be consistent with the tax policy underlying section 55. ...

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024-- summary under Section 11.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part II- Section 11.1 Administrative arrangement with the Canadian Dental Association Under the CRA arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances and claim input tax credits (ITC) accordingly – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

. … The expression not ordinarily located primarily means ordinarily located 50% or less. ...

. … 4(b) [Provincial exemptions] With the exception of Quebec, the CRA does not necessarily abide by the provincial exemptions when determining the rate to issue administrative garnishment action. ... Some examples…include situations where there were other sources of income and only one income source was to be subjected to garnishment action, assets that could be readily available to the debtor to generate funds to satisfy the tax debt in full or a substantial portion and the debtor was not cooperating, or situations where the provincial exemption amount would be insufficient to address the amount of arrears. … [T]he CRA felt it was better to treat all debtors, in a similar circumstance, the same to the extent possible. ...

. … A significant number of NPOs violate the incidental profit test or have large equity The results from the review of the randomly-selected organizations suggest that a significant portion of incorporated organizations would fail to meet at least one of the requirements set out in paragraph 149(1)(l)…. ...

. … 3. Where the insurance policy provides a taxpayer carrying on business or practising a profession with a benefit for loss of income earning capacity such as income disability insurance, the premium on such a policy is a personal and living expense which is non-deductible and the benefit received by the taxpayer is not considered to be income subject to tax in his hands. 4. ...

. … Since B Co already owns the logs, the amounts paid by B Co are not consideration for a supply of logs by A Co but would appear to be [taxable] compensation paid to A Co for cutting the timber. ...

. … [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...