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

CRA responded: [G]enerally … “benefits” are received qua shareholder where that person can significantly influence the corporation’s business policy. ...

In accordance with Abrahamson … the fact that the original source of funds in a foreign individual retirement plan was a pension plan is not relevant. ...

. … [T]he individual will be considered to have received a pension benefit equal to the fair market value of the annuity contract at the time the individual acquires it and must include this amount in their income under subparagraph 56(1)(a)(i). ...

CRA responded: A corporate beneficiary of a trust in respect of which a [s. 104(19)] designation is made is … deemed to have received the dividend for the purposes of section 55 and can benefit from the safe income exception in paragraph 55(2.1)(c). ...

. … [T]he fact that provincial insurance law may exempt a charitable organization from the application of certain legislative requirements with respect to the issuance of charitable gift annuities does not amount to the organization being licensed or otherwise authorized under that law to carry on an annuities business in Canada. ...

The bonuses described in examples 4 and 6 of the … Folio [S3-F10-C3] and the rebates of mutual fund commissions discussed at paragraphs 3.36 and 3.37 are (or are analogous to) a return on the amounts invested from the registered plan with the financial institution. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

28 September 2020 External T.I. 2019-0800551E5- Provincial Residency of a TFSA Trust-- summary under Subsection 2601(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(2) office of investment manager was PE to which securities trading income of TFSA was allocated When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control was factually exercised by the trustee – irrespective of the level of involvement of the TFSA holder in the decisions. ...

Since the benefit … arises from the issuance of shares, paragraph 7(3)(b) precludes a deduction by EmployerCo in respect of that benefit. ...