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

26 June 2024 External T.I. 2023-0961541E5- Retiring allowance – instalment payments-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance retiring allowances can be paid in instalments over an extended period of years Is a retiring allowance, that is paid in instalments, required to be paid within a certain period of time after the termination of employment? ...

11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e)-- summary under Paragraph 87(2)(j.6) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(j.6) s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules S. 84.1(2.3)(a)(i), as part of the former (private-member bill) intergenerational business transfer rules, provided that if, otherwise than by reason of death, the children’s purchaser corporation disposed of the subject corporation shares within 60 months of their purchase, the exception in s. 84.1(2)(e) from the application of s. 84.1 was nullified. 2022-0953991E5 indicated that, consequently, if the purchaser corporation amalgamated, within the 60-month period, with the subject corporation, then the resulting disposition pursuant to s. 87(11)(a) of the subject shares engaged the s. 84.1(2.3)(a)(i) exclusion. ...

18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

2 July 2013 External T.I. 2012-0454251E5- 149(1)(l) – donations to capital fund-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) sale of naming rights Generally, an organization referred to under s. 149(1)(l) will not lose its s. 149(1)(l) exemption for collecting donations from members or from businesses affiliated with its members for use in a capital project that furthers the organization's non-profit purposes, nor will it lose its exemption for maintaining a "wall of honor," naming rights, or similar systems for recognizing such contributions, providing that such recognition has only nominal value. ...

4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans The employees of Corporation A were members of four basic insurance plans respecting health insurance, salary insurance and accidental death and dismemberment insurance available to employees of employers in a particular industry. ...

4 March 2015 External T.I. 2014-0562151E5 F- Frais de psychothérapie – dépense d'entreprise-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose “but for” test applied to determine deductibility/potentially creditable item can instead be expense In the course of a business of offering psychology services, a psychologist incurs psychotherapy fees in order to reduce such therapist's personal reaction to the sessions conducted with clients. ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y)-- summary under Paragraph 95(2)(m) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(m) Canco has a 51% interest in a partnership ("Partnership") holding all the shares of Forco1 which, in turn, owns all the shares of Forco2. ...

17 July 2013 External T.I. 2012-0473261E5 F- Actif d'impôts futurs / Future income tax assets-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share future (or deferred) income tax asset is not an asset until it becomes receivable, whereupon it may be attributable to active business Is a future income tax asset an asset that is used principally in an active business carried on in Canada for purposes of the "qualified small business corporation share" ("QSBCS") and "small business corporation" ("SBC") definitions? ...

21 November 2014 External T.I. 2014-0536771E5 F- Supplément pour frais médicaux – Revenu modifié-- summary under Cohabiting Spouse or Common-Law Partner Summary Under Tax Topics- Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner surviving spouse is not living separate and apart from deceased spouse at year end Where a "cohabiting spouse or common-law partner" dies during a taxation year, is the income of the deceased spouse included in the computation of the refundable medical expense supplement ("RMES") of the surviving spouse; and is the surviving spouse's income included in the calculation of the RMES in the terminal return of the deceased spouse? ...

18 October 2012 External T.I. 2012-0436181E5- Part IV Tax / Denied Dividend Refund-- summary under Subsection 129(1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1) no requirement that "refund" be received There is a cross-redemption of preferred shares held by two connected corporations (Aco and Bco) in each other, thereby giving rise to Part IV tax based on their respective dividend refunds (which, in these circumstances, are generally determined on a circular basis). ...