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
Results 301 - 310 of 1645 for 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
Technical Interpretation - External summary
28 February 2001 External T.I. 2000-0016765 F - All or substantially all -- summary under Clause 110.6(14)(f)(ii)(A)
28 February 2001 External T.I. 2000-0016765 F- All or substantially all-- summary under Clause 110.6(14)(f)(ii)(A) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(ii)- Clause 110.6(14)(f)(ii)(A) all or substantially all test in s. 110.6(14)(f)(ii)(A) is generally but not always a 90% of FMV test Regarding the meaning of the expressions “all or substantially all the assets used in an active business” in ss. 110.6(14)(f)(ii)(A) and 54.2, CCRA stated: FMV is generally the best measure for calculating “all or substantially all of the assets” of a business for the purposes of those provisions …. However … other units of measurement could apply since those provisions of the Act do not state any particular unit of measurement that must be used. ...
Technical Interpretation - External summary
3 November 2017 External T.I. 2017-0712141E5 F - Borrowing to make interest-free loans -- summary under Subparagraph 20(1)(c)(i)
After referencing the general principle that “interest expense on borrowed money used to make an interest-free loan … may be deductible … where the facts disclose that the money was borrowed for an indirect current use whose purpose was the earning of income from a business or property,” CRA stated: The CRA generally agrees that this is the case where, firstly, the interest-free loan affects the corporation's capacity to earn income and, furthermore, the interest-free loan is granted to a corporation by its sole shareholder or, if there are several shareholders, each shareholder has granted an interest-free loan to the corporation in proportion to the shareholder’s interest in the corporation. ... In this regard, the principles followed in … Canadian Helicopters … could be useful. ...
Technical Interpretation - External summary
19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie -- summary under Paragraph (d)
. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...
Technical Interpretation - External summary
19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie -- summary under Paragraph 148(10)(d)
. … According to paragraph 148(10)(d), a policyholder is deemed not to have disposed of or acquired an interest in a life insurance policy as a result only of the exercise of any provision of the policy. Generally, the … CRA … considers that the change of beneficiary, in and of itself, does not constitute an amendment that results in a disposition of the life insurance policy. ...
Technical Interpretation - External summary
12 July 2018 External T.I. 2018-0755471E5 - Half-brothers and related persons -- summary under Paragraph 251(6)(a)
See, for example … Diktakis …. As such, half-siblings would qualify as being connected by a blood relationship since they are individuals who have a common parent …. ...
Technical Interpretation - External summary
25 February 2004 External T.I. 2003-0042461E5 F - Invalidité d'un actionnaire/admin./employé -- summary under Paragraph 6(1)(a)
In addition … the payment of premiums … would not result in a taxable employee benefit … or a taxable shareholder benefit … because the corporation is the recipient of the insurance benefits. ...
Technical Interpretation - External summary
18 February 2008 External T.I. 2006-0205321E5 F - BAA-corpropriété indivise, QFP-undivided interest -- summary under Qualified Farm or Fishing Property
In finding (contrary to an earlier position) that their respective co-ownership interests could constitute qualified farm property, CRA stated: [T]he term "property" is defined very broadly in subsection 248(1) and … includes an undivided interest of a co-owner in an immovable. … Consequently … an undivided interest in an immovable is, for the purposes of the Act, included in the expression real or immovable property in subsection 110.6(1). ...
Technical Interpretation - External summary
26 November 2010 External T.I. 2008-0299301E5 F - Sommes reçues par des médecins résidents -- summary under Subsection 5(1)
. … [I]t is necessary to look for the presence of a certain number of supervisory indicators … including … mandatory presence at a workplace, more or less regular work assignment, imposition of rules of conduct or behaviour, requirement for progress reports and control of the quantity or quality of work performed. … [I]t would appear that the relationship between the medical residents and the health care facility is one of employer-employee. ...
Technical Interpretation - External summary
19 November 2001 External T.I. 2001-0098455 F - Employés à l'étranger - production de T4 -- summary under Subsection 200(1)
In confirming that Canco is still required to issue T4s to them, and after referring to s. 153(1)(a) and Reg. 200(1), CCRA stated: [I]t is not necessary for the person paying the salary or wages be the employer of the taxpayer to whom the salary is paid (see, inter alia, Coopers & Lybrand …) or for the taxpayer to be taxable in Canada or resident in Canada. … [T]he amounts paid to the Employees appear to constitute salaries or wages within the meaning of subsection 248(1). ...
Technical Interpretation - External summary
28 May 2021 External T.I. 2021-0889611E5 - ACB and Safe income allocation on corporate reorg. -- summary under Paragraph 55(2.1)(c)
DSI of Holdco 2 after reorg: (DSI of Holdco 2 prior to reorg ($10) + $72 DSI considered to have been received from Opco per 2 above) x net cost amount of assets considered retained by Holdco 2 ($37 per 3 above, plus the $20 cost of other assets, totaling $57) / (net cost amount of assets of Holdco 2 “prior to” [sic] reorg ($57) + net cost amount of assets considered to have been received from Opco ($100 cost of Property 1)) = 82 x 57/157 = $30. 5. DSI of Holdco 2 considered to be transferred to Holdco 1: $82 – $30 = $52. 6. ... DSI of Holdco 1 after reorg: DSI of Holdco 1 prior to reorg ($1,000) + amount considered to have been received from Holdco 1 ($52) = $1,052. ...