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

The TFSA contract requires the maintenance of an asset minimum (described as a “margin call provision … “in order to secure the loan”), i.e., so that the nephew cannot liquidate the TFSA unbeknownst to his uncle. ...

CRA indicated: [W]here an employee works at a very great distance from the employer's place of business because of the requirements of the employment and not because of the personal choice made by the employee … the travel made by the employee between the employee’s place of work and the employer's place of business is travel made in the performance of the duties of the employee's office or employment. ...

In applying the surrogatum principle … the amount paid by the employer- to replace an amount that would not have been taxable- should not be taxable either. ...

Even if subsection 75(2) no longer applied, the attribution rules in sections 74.1 and 74.2 would have to be considered …. ...

Paragraph 20 of IT-73R6 … indicates that the CRA considers a business carried on by a corporation as a member of a partnership not to be a SIB if the partnership employs more than five full-time employees, and that, accordingly, the corporation's share of the income from the business can be included in the calculation of its "specified partnership income" ("SPI"). ...

After noting its position in IT-145R that “the execution of orders from bulk stock is not considered a processing activity where the activities involved consist solely of counting or measuring and repackaging” and the position in Tenneco that “the goods must undergo a change in form, appearance or nature” in order for there to be processing, CRA stated: [A]lthough the taxpayer's processing activities have the effect of making … [the] products more marketable, we do not believe that there has been any change in the form, appearance or other characteristics of the products..... ...

However … the filing of a valid election pursuant to subsection 110(1.1) would enable the employee in this situation to claim a deduction under paragraph 110(1)(d) provided that all of the other conditions of this paragraph are met. ...

. … [T]he issuance of the first certificate of competence is an indicator that an apprentice is eligible. ...

On the issue of whether a subsection 83(2) election is available to a corporation in respect of a dividend that it is deemed to have paid pursuant to paragraph 84.1(1)(b), we are of the view that such an election is available if such a dividend becomes payable by a private corporation to a shareholder who already holds shares of any class of the corporation's capital stock …. ...

CRA responded: The 2006 Federal Budget announced an increase in the scholarship and bursary exemption so that … a student can no longer deduct moving expenses where the student’s income is derived solely from scholarships or fellowships. ...