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 paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not … restrict the contributions necessary to fund an RCA. ...

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...

. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

. … While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...

. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...

For example [there would be such] benefit … if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...

. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...

. … Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...

21 November 2001 External T.I. 2000-0062895 F- BOURSE D'ETUDES OU REVENU D'EMPLOI-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee – but could be non-taxable as primarily for employer’s benefit A professional services firm recruits university students and offers them a sum of money to cover the cost of their studies. ...

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved The shareholders of a Canadian-controlled private corporation (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis – but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price in one year’s time as compared to the portion of the sale price allocated to such shares. ...