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

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance-- summary under Paragraph 73(1.01)(c) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(c) funding of life insurance policy is a benefit where proceeds to be paid to non-spouse In finding that the use of income or capital from a purported spousal trust to pay life insurance premiums on spouse's life would disqualify trust from inception, CRA stated: [T]he relevant legislation does not contain a requirement that the spouse “benefit” from the trust while alive.... ...

2 October 2015 External T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche-- summary under Paragraph 110.6(1.3)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

6 May 2016 External T.I. 2016-0646411E5- Professional corporation & small business deduction-- summary under Specified partnership income Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified partnership income rulings for the multiplication of the small business deduction by professionals’ service corps will cease to apply CRA noted that the 2016 Budget proposes to extend the specified partnership income rules to partnership structures in which a Canadian-controlled private corporation (“CCPC”) provides (directly or indirectly, in any manner whatever) services or property to a partnership during a taxation year of the CCPC where, at any time during the year, the CCPC or a shareholder of the CCPC is a member of the partnership or does not deal at arm’s length with a member of the partnership (and that the Budget rules extend to comparable private corporation structures). ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Exempt Trust Summary Under Tax Topics- Income Tax Act- Section 233.2- Subsection 233.2(1)- Exempt Trust Australian Superannuation Fund not an exempt trust due to taxability An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Regulation 202(1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 202- Regulation 202(1)- Regulation 202(1)(c) all capital distributions made by Canadian-resident trusts to a non-resident beneficiaries must be reported on NR4s Does Reg. 202(1) require a Canadian-resident trust to report a capital distribution to a non-resident capital beneficiary? ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Subparagraph 220(4.5)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.5)- Paragraph 220(4.5)(a)- Subparagraph 220(4.5)(a)(i) s. 85(1) rollover of the property triggered the s. 220(4.5) deferred tax On his emigration from Canada, Mr. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Paragraph 85(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1)- Paragraph 85(1.1)(b) partnership interest is eligible property After emigrating from Canada, an individual transferred his interest in a real estate partnership on a s. 85(1) rollover basis to a corporation of which he was the sole shareholder. ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Subparagraph 181(3)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3)- Paragraph 181(3)(b)- Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as liabilities, labelled as "customer deposits and deferred revenue". ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Paragraph 181.2(3)(c) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3)- Paragraph 181.2(3)(c) customer advances received by travel agents and reported as deferred revenue in their balance sheets were “advances” Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as deferred-revenue liabilities. ...

21 January 2008 External T.I. 2007-0227531E5 F- GRIP / GRIP Addition for 2006-- summary under Subsection 89(14) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14) for 2006 only, CRA accepted designating a portion of a dividend as an eligible dividend Where, in 2006, Bco's GRIP is $1.3 M and, pursuant to s. 84(3), Bco is deemed to have paid a dividend of approximately $1M to Cco and Dco (approximately $500,000 each), can Bco designate a fraction of the deemed dividend representing Bco's safe income on hand attributable to the purchased shares (approximately $700,000) as an eligible dividend, pursuant to s. 89(14)? ...