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

CCRA noted that where there was not a new plan, then it would be possible for individuals who eventually receive disability insurance benefits to deduct the contributions made in the years prior to the event – but if there was a new plan, they would only be able to deduct their contributions since the start of the new plan. ...

. … Thus, an RCA trust will be required to include in computing its refundable tax at the end of a taxation year the amount of interest required to be included in computing income from property pursuant to subsections 12(3) and 12(4) and paragraph 12(1)(c) for the year or for a preceding taxation year. ...

. … [T]he Proposal does not prevent Mr. A from selling his shares. Indeed, the Proposal is an agreement independent of the agreement to sell the Corporation’s shares and the sale of the shares must take place in order for the creditor payment clause of the Proposal to apply. ...

Furthermore, we are of the view that the French and English versions of paragraphs 256(3)(a) and 256(6)(a) have the same meaning and that the expression "under which" used in the English version does not allow for a broader interpretation of the verb "stipuler" used in the French version …. ...

. … [T]he fees paid by the corporation for the principal shareholder should be included in the principal shareholder's income pursuant to subsection 15(1). ...

Second, a corporation that receives an eligible dividend from a payer corporation is subject to Part IV tax whether or not the payer corporation receives the DR – so that if CCRA allowed a corporation to waive a DR, this would have no effect on the Part IV tax payable by the other corporation. ...

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

. … [T]he provisions of section 22 of the Regulation will not, in and of themselves, prevent the deduction of interest on money borrowed to acquire common shares of a QBIC if there is otherwise a reasonable expectation, at the time the shares are acquired, that the holder of the common shares will receive dividends. ...

. … [T]he direct use of the borrowed money is for personal purposes, which is not an eligible use. ...

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...