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

. … The wording of the Act does not require that the corporation employ more than 5 full-time employees throughout the year, but rather that it employ more than 5 full-time employees in the business throughout the year. ...

. … Computer software that is downloaded does not meet the characteristics of shrink-wrapped software. ...

. … [T]he expenses incurred by the taxpayer in suing his employer may not be deductible because the taxpayer did not receive compensation for the employment income lost during the suspension period. ...

20 August 2002 External T.I. 2002-0145225 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) s. 251(5)(b) not applied iteratively, where shareholders have a pro rata right to acquire another’s shares, and a contingent right to acquire those shares not taken up in the 1st round Situation 1 The shareholders' agreement between the five equal shareholders of Opco provides an obligation of each to sell its Opco shares equally to the others on the occurrence of specified events of fault such as, theft, bankruptcy a breach of any of the provisions of the agreement – but with provision for any shares not so taken up by one of the other shareholder to be divided equally for purchase by the other acquiring shareholders. ...

Consequently … the hypothecary creditor will not be able to include in the calculation of its capital dividend account the proceeds of a life insurance policy that it has received in payment of the debtor policyholder's debt because such proceeds are received only by the policyholder. ...

. … [T]he trips made by Employee A between his home and the Y service point on Tuesday and Thursday of each week are of a personal nature. ...

5 December 2002 External T.I. 2002-0172315 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) ss. 251(5)(b) and 256(1.4) applicable where the 3 equal shareholders agree that they must purchase the shares of anyone committing fraud – but not if redemption requirement The three equal unrelated individual shareholders of Opco (Messrs. ...

In the current situation … the estate replaces the taxpayer. …[I]t would therefore be possible for the estate to deduct from its income the amount of damages paid if it results from acts engaged in by the entrepreneur while carrying on his business and if this amount of damages is otherwise deductible in accordance with the requirements of IT-467R2-Draft ...

Thus … the block size would be 100 and thus if there were 100 unitholders of the first series each holding at least 100 units, and there would have to be at least 50 unitholders of the second series, each holding at least 100 units. ...

Before indicating that such fee could be deducted in accordance with s. 20(1)(e) provided that it was “incurred in the course of borrowing money used to earn income from a business or property and that it [was] reasonable,” CRA stated: [P]aragraph 20(1)(e.1) … does not have application because the guarantee fee is paid in respect of the term of the loan rather than with respect to the year in which it is paid. ...