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

& Disc. Div. Shares-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) payment of dividends on discretionary dividend shares with no liquidation entitlement would not result in a significant reduction Two brothers each holding half of the shares (being common shares) of Opco, formed respective Holdcos, which subscribed for one newly-created Class F share of Opco. ...

17 January 2020 External T.I. 2017-0685341E5- Tax Comparison of the FIT & Net Metering Programs-- summary under Class 43.1 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.1 general Class 43.1 or 43.2 treatment of specified energy property rules to equipment used in the Ontario Feed-in Tariff program Under the Feed-in Tariff and microFIT programs (the “FIT/micro-FIT Programs”) administered by the Ontario Power Authority (the “OPA”), a participant contracts with the OPA to supply the electricity generated from approved renewable energy project to the provincial electricity distribution system at a charge for each kWh of electricity generated regardless of whether electricity is subsequently consumed by the participant. ...

2 June 2020 External T.I. 2020-0847081E5 F- Compte de frais médicaux – période de report-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan during COVID-19, unused HCSA credits can be carried forward for up to an additional 6 months Due to the COVID-19 pandemic, plan members of a health care spending account (“HCSA”) may not be able to incur eligible medical expenses or use the credits allocated to the HCSA before they expire, so that they will be forfeited. ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) example of application of s. 7(1.31) to acquisition and immediate sale of shares pursuant to RSUs An employee who acquired 10 common shares of the employer, a public corporation, on capital account, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 47(3) Summary Under Tax Topics- Income Tax Act- Section 47- Subsection 47(3) application of ss. 7(1.31) and 47(3) to the acquisition and immediate sale of RSU shares S. 7(1.31) applies in relation to shares of a public corporation if a share of the corporation is acquired under an agreement described in s. 7(1), an identical share is disposed of within 30 days after that acquisition, no other identical shares are acquired or disposed of by the employee after that acquisition and before the disposition, and the employee makes the required designation. ...

5 March 2024 External T.I. 2023-0962831E5- Active business income – Income from solar panels-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business income from solar array panel might not be income from property, so that there was no SIB The sole business activity of a Canadian-controlled private corporation (the “Corporation”) was to build a small utility-scale solar array on bare land and sell the electricity that was generated to a local utility service under the terms of a long-term contract. ...

11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp 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 deemed never to have applied. 2022-0953991E5 F 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) by the purchaser of the subject shares would engage the s. 84.1(2.3)(a)(i) exclusion. ...

28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4)-- summary under Paragraph 256(1.4)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) s. 256(1.4) technically applies where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Four unrelated individuals (A, B, C and D) each hold 25% of the shares (being common shares) of Opco through their respective wholly-owned holding companies (Aco, Bco, Cco and Dco). ...

17 January 2007 External T.I. 2005-0152601E5 F- Politique d'application RS & DE 1996-02-- summary under Paragraph 37(1)(a) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a) LGL and Tigney pro rata approach to in-Canada requirement What was the impact of the LGL decision (99 DTC 675, aff’d [2000] FCA No. 166) on Case C of Application Policy 1996-02- Testing and Studies Required to Meet Requirements in Regulated Industries, which read: The testing or engineering is performed in Canada to meet regulatory requirements, but the project is conducted outside Canada. ...

17 January 2020 External T.I. 2017-0685341E5- Tax Comparison of the FIT & Net Metering Programs-- summary under Subsection 1100(25) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(25) application of exception to the specified energy property rules to equipment used in the Ontario Feed-in Tariff program Under the Feed-in Tariff and microFIT programs (the “FIT/micro-FIT Programs”) administered by the Ontario Power Authority (the “OPA”), a participant contracts with the OPA to supply the electricity generated from approved renewable energy project to the provincial electricity distribution system at a charge for each kWh of electricity generated regardless of whether electricity is subsequently consumed by the participant. ...