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

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS-- summary under Qualifying Home Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home Regarding the purchase of a unit that consisting of a leasehold interest in the property and a number of shares in the corporation that owns the property, CCRA noted that advance rulings had found that a unit consisting of a leasehold interest and shares, and giving its holder the right to the personal enjoyment of the housing unit would be a housing unit for the purposes of the definition of "principal residence", and that the acquisition of such a unit could qualify as a qualifying home for HBP purposes. ...

7 February 2000 External T.I. 2000-0000555- NURSING HOME FEES-FOOD & ACCOM.-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) "Generally, all regular fees charged by a nursing home, including any component for accommodation or meals, are normally accepted as being on account of full-time care in a nursing home. ...

19 March 2001 External T.I. 2001-0063345 F- RS & DE- MANDATAIRE-- summary under Clause 37(1)(a)(ii)(E) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(E) organization did not qualify under s. 37(1)(a)(ii)(E) because it made disbursements only as agent The applicant did not qualify under s. 37(1)(a)(ii)(E) because it disbursed amounts to other entities only as agent for taxpayers and thus did not “carry on activities that consist of receiving amounts from taxpayers, other than as an agent of the taxpayers, and redistributing those amounts to the associations, institutions or corporations referred to in clauses 37(1)(a)(ii)(A) to (C).” ...

15 January 2021 External T.I. 2020-0847781E5- CEWS- remuneration / SSUC- rémunération-- summary under Eligible Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Eligible Remuneration non-cash taxable benefits are not “eligible remuneration” An “eligible employee” of an eligible entity excludes an individual who is without remuneration by the eligible entity in respect of 14 or more consecutive days in a qualifying period ending before July 5, 2020. ...

5 September 2002 External T.I. 2002-0147315- PARTNERSHIP AS A PARTNER & 98 (3)-- summary under Subsection 98(3) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(3) lower-tier partnership wind-up Can s. 98(3) be used where one (or all) of the partners in the particular partnership are themselves partnerships? ...

26 July 2012 External T.I. 2011-0431681E5- Taxable Benefits – Recreational Facilities-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) CRA stated: [A] taxable benefit would not generally arise in situations where an employer provides an in-house recreational facility and the facility or membership is available to all employees. ...

4 March 2015 External T.I. 2014-0537941E5- Non-Profit Organization – fibre-optic cable-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) substantial fibre-optic cable network likely not consistent The Institute, a not-for-profit organization, received a provincial grant and subsequently accessed provincial debentures to finance the construction of a substantial fibre-optic cable network. ...

6 December 2012 External T.I. 2012-0461711E5 F- Paiements indirects / Indirect payments-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) 56(2) inapplicable to incorporated artist respecting producer paying mandatory contributions to the fund for the artist’s union A producer who retains the services of an incorporated performing artist is required to pay a percentage of the fees otherwise payable by it to the artist’s Corporation (respecting the services performed by the artist as an employee of the Corporation) directly to the benefits plan (the “CSA”) for the Union des Artistes (UDA). ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F proceeds of CRP upon entering into oil and gas lease The taxpayer inherited subsurface exploration rights from his father with a deemed cost under s. 70(5.2) equal to their fair market value, and leased those rights to a corporation for a lump sum. ...

13 February 2013 External T.I. 2011-0430921E5 F- S. 261- Loss carry-back & loss carry-forward-- summary under Subsection 261(12) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(12) conversion to U.S. dollar and back again changed non-capital losses The taxpayer elected in its December 31, 2009 taxation year to adopt the U.S. dollar as its functional currency in accordance with s. 261(2), and revoked that election in its December 31, 2011 taxation year in accordance with s. 261(4). ...