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

4 May 2005 External T.I. 2005-0120271E5 F- Change of Control- CDA & RDTOH-- summary under Clause 256(7)(a)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a)- Subparagraph 256(7)(a)(i)- Clause 256(7)(a)(i)(A) s. 256(7)(a)(i)(A) applied where taxpayer acquired shares of CCPC from his sister Ms. ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) income to preferred beneficiary is not split income A trust that is a limited partner of a partnership (“LP”) providing back office support to a general partnership of accounting professionals (“Partnership”) as its only source of income has a minor disabled beneficiary who qualifies as a “preferred beneficiary.” ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) split income rules do not apply to preferred beneficiary income The definition of split income includes trust income distributions under s. 104(13) but not preferred beneficiary amounts under s. 104(14). ...

1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) right to accrued but undeclared dividends was not a separate eligible property from the preferred shares Before indicating that a preferred share with accrued cumulative dividends could be transferred by an individual to a holding corporation under s. 85(1) or exchanged for other shares of the corporation pursuant to a reorganization of capital described in s. 86(1) without the accrued dividends being recognized as income, Revenue Canada rejected the position that such accrued dividends would be an eligible property separate form the shares themselves, stating: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) "It is a question of fact whether a taxpayer, who is a resident of a foreign country and who is present in Canada for more 182 days in a year, sojourns in Canada for more than 182 days in that year. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 "Where a U.S. resident who is not a factual or deemed resident of Canada exercises his employment in Canada, his employer... is required to withhold source deductions in respect of the employment under subsection 153(1) of the Act even if the remuneration received by such an individual is exempt from Canadian taxation by virtue of paragraph 2 of Article XV of the Convention. ...

16 July 1996 External T.I. 9604915- 55(2)-NOT APPLY WHERE SALE & REDMPTION DIFFERENT SERIES.-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Where preferred shares issued by Newco on the roll-in to Newco of shares of Opco, have a dividend entitlement equal to dividends received by Newco on the shares of Opco, and to proceeds received by Newco on the sale of shares of Opco to the extent of the gain realized by Newco, but with the redemption amount of the shares being reduced on a dollar-for-dollar basis by the amount of the dividends paid out of such gain. ...

26 March 2001 External T.I. 2001-0073495- MANUFACTURING & PROCESSING-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits After noting that the "processing of goods usually refers to a technique of preparation, handling or other activity designed to effect a physical or chemical change in an article or substance, other than natural growth", and that examples included galvanizing iron, dyeing fence posts, dehydrating foods and modernizing and pasteurising dairy products, the Agency indicated that "a recycling facility would generally qualify for the manufacturing and processing profits deduction.... ...

14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property-- summary under Agency Summary Under Tax Topics- General Concepts- Agency criteria applied for determining presence of agency Before confirming that ticket sales receipts of the taxpayer may have been generated as agent for charitable organizations, so that they did not generate income to the taxpayer, CCRA stated: In general, the CCRA agrees to recognize a principal-agent relationship between persons for tax purposes provided that: the relationship between the persons concerned is legally one of principal-agent; this implies, among other things, that the transactions relating to the agency are effective and complete from a legal standpoint; this relationship arises from a prior formal agreement and does not constitute an ex post facto arrangement; this relationship does not contravene any legislation; the relationship is not a sham; the relationship is disclosed to the CCRA and the relevant documents are provided to the CCRA at the appropriate time (generally when the relevant tax returns are filed); the facts of the particular situation support the existence of the principal-agent relationship between the persons concerned. ...

4 May 2021 External T.I. 2020-0853361E5 F- Frais d'asepsie / asepsis fees-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) additional dentists’ charges for COVID precautions qualified Regarding fees paid to a dentist for additional “asepsis” provided during the oral examination and treatment of children's cavities during the COVID pandemic, i.e., for additional procedures that prevent COVID infection such as personal protective equipment (gloves, mask, protective glasses, lab coat, etc.), cleaning, disinfection and sterilization, CRA stated: [A]n individual's eligible medical expenses include fees paid to a dentist for dental services provided to the individual, the individual's spouse or common-law partner, or a dependant of the individual, in the taxation year in which the fees were incurred. ...