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

After referring to s. 37(13), CRA stated: [A]dministrative support tasks in respect of the activities of a subsidiary of a taxpayer would not be considered to be SR&ED of the taxpayer because the condition in paragraph 37(13)(b) is not satisfied since the administrative support tasks would not be SR&ED of the subsidiary …. ...

In rejecting this proposition, CRA stated that “it is clear that the preferred shares … were not held by the particular individual on April 26, 1995, notwithstanding that the preferred shares would be deemed to be substituted property for the common shares,” and also noted that a stock dividend did not come within the continuity provisions of s. 131(12) of the amending Bill. ...

. … [O]ne item that generally reduces the adjusted cost basis [of the policy] is the "net cost of pure insurance", as defined in subsection 308(1) of the Income Tax Regulations, calculated immediately before the end of the calendar year ending in a taxation year commencing after May 31, 1985, in respect of an interest in a life insurance policy (other than an annuity contract) last acquired after December 1, 1982. ...

. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...

. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...

. … [A]ny amount so deducted by the Corporation would reduce the Foreign Tax Credit under subsection 126(1) and thus no longer affect the calculation of its RDTOH. ...

. … Premiums paid by the corporation for the rider to the policy allowing it to obtain a premium refund amount if the shareholder does not have one of the covered illnesses or medical conditions after 10 years are not deductible on the basis of the application of paragraphs 18(1)(a) and 18(1)(h). ...

For example … negotiating a collective agreement would not include the duties of ensuring its application and representing the union's employee members in a grievance. ...

Beaudoin … 2004 DTC 2414, held that the payment of funds from an RRSP to pay a debt extinguished by the order of discharge of a bankrupt does not constitute the receipt of a benefit by the bankrupt within the meaning of subsection 146(8), since the bankrupt does not receive any money or benefit as a result of that payment. ...

. … [T]he Canadian citizen to whom you refer in your request will be able to benefit from the exemption for the gain realized on the disposition of the residence located in France to the extent that a person with French nationality whose situation in fact and in law is identical to the individual’s own could benefit from it. ...