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

In accordance with [Reg.] 4901(1) … a prescribed investment for a registered investment … is a qualified investment for … a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in … [ss.] 146(1), 146.3(1) and section 204 … [and Reg.] 4900 …. ... In addition [see] paragraph 21 of … IT-320R3 …. ...

CCRA responded: [T]he situation … is similar to … Grenier …. Consequently, subject to additional facts to the contrary, … the interest paid … could be deductible pursuant to paragraph 20(1)(c). ...

CRA responded: [P]ursuant to subparagraph 152(4)(b)(i), paragraph 152(6)(f.1) and subsection 152(4.01) … an assessment to take into account a foreign tax credit under subsection 126(2.21) of the Act in respect of foreign taxes paid is permitted only where the assessment is made within 3 years after the normal reassessment period. ... …The Minister is not obligated to reassess a return simply because a waiver is filed by a taxpayer for a particular taxation year …. [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. … … 2016-066042 … opined that if any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) of the Act, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

The second fund is … a "NISA Fund No. 2 " …. Generally, a taxpayer must include in computing income for a taxation year from property by virtue of subsection 12(10.2) the total of all amounts paid to the taxpayer from the taxpayer's NISA Fund No. 2. ...

CRA indicated that: “based on the context in which the RUTT regime was introduced … the definition of a RUTT should be interpreted broadly. ... The CRA Guidance stated that uncertainty is reflected in the financial statements, for example, if “the entity concluded it is not probable that the tax authority will accept an uncertain tax treatment and thus … it is probable that the entity will receive or pay amounts relating to the uncertain tax treatment ….” ... When that is the case, the RUTTs must be disclosed in Form RC3133 …. … [T]he notes to the audited financial statements prepared in accordance with … IFRS … or any other country-specific generally accepted accounting principles need to be considered when determining whether the uncertainty of tax treatments is reflected in the relevant financial statements …. ...

This interpretation is consistent with [9422630] …. Since … the trust indenture indicates that the trustees shall act in a manner that promotes or supports the purposes for which the trust was created, the granting of annuity contracts by the trust is part of a strategy to increase its gift income and enable it to achieve its purposes, even though the trust indenture contains no specific reference to the provision of such annuity contracts. … [T]herefore … subsection 75(2) applies …. ...

CRA responded: As described in … S1-F2-C3 … 3.94 … materials related to the program includes the cost of items that are essential for the completion of the program and are expected to have a lifespan use generally limited to the program length, such as books, lab coats, brushes and paints. ...

Furthermore, where the corporation is the beneficiary of a policy acquired to finance a share purchase/redemption under a shareholders' agreement … the premiums are not made or incurred for the purpose of earning business income as required by paragraph 18(1)(a) or paragraph 18(1)(h). ... If a critical illness policy were used as collateral for a corporate loan, the premiums would also be non-deductible …. Antoine Guertin …. … Premiums paid by the corporation for the rider to the policy allowing it to obtain a premium refund amount if the shareholder does not have one of the covered illnesses or medical conditions after 10 years are not deductible on the basis of the application of paragraphs 18(1)(a) and 18(1)(h). ...

That is what the Tax Court of Canada indicated in … Ekamant … 2009 TCC 408 …. Thus … Corporation A did not become a CCPC at the time of the signing of the purchase offer made by Corporation B since it continued to be controlled by Pubco at that time. ...

A, Holdco A and Trust A sell ½. ½ and ¼, respectively, of their shares of Corporation A on a s. 85(1) rollover basis in exchange for similar-attribute shares of Newco. ...