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]n a situation where an amount of money is donated to a school board by a donor for the purchase of books at the request of the donor for use by all students in a school community attended by a person related to the donor, it is our view that the donor will generally not receive an advantage. ...

. … The fact that a trustee guarantees bank loans made to the trust does not, in itself, give rise to the application of the provisions of subsection 75(2). ...

After finding that this credit was not required to be included in income under s. 12(1)(x.2), CRA noted that it: has taken the position in the past that the RDCL does not reduce cumulative Canadian exploration expenses ("CCEE") and cumulative Canadian development expenses ("CCDE"), on the basis that the RDCL was too remote from the Canadian exploration expense ("CEE") and Canadian development expense ("CDE") and therefore did not have a sufficiently direct connection to the CEE and CDE incurred by the particular corporation to fall within element J of the definition of CCEE in subsection 66.1(6) and the description of M in the definition of CCDE in subsection 66.2(5) …. ...

. … The fact of incurring a loss is the only real condition to be satisfied in order to claim an RDCL amount. ...

. … [T]he word “income” in this section refers to “net income”. Accordingly, if expenses are disproportionately allocated when calculating the income described in subparagraph (a)(i) of the definition of SCI in subsection 125(7) for the year …[o]nly the expenses that are reasonable to consider to be attributable to the activities generating the income described in subparagraph (a)(i) of the definition of SCI should be considered. ...

Cash balances which accumulate only to be depleted in accordance with the annual seasonal fluctuations of the business will generally qualify – but a permanent balance in excess of the company's reasonable working capital needs will generally not qualify. ...

. … [T]he taxable capital gain in respect of any subsequent increase in value of the mutual fund units from the date of death to the date of disposition by the GRE to the qualified donee will also be equal to zero pursuant to subparagraph 38(a.1)(i). ...

However, CRA went on to indicate that the taxpayer’s exemption threshold in this situation would be nil “it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply.” ...

. … It is the CRA’s view that the intrinsic value of an option is not reflective of its FMV; rather, a valuation method that is appropriate in the circumstances should be used to determine the FMV. ...

Therefore … in the example above, the CRA would not assess interest. ...