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

The formula to do the allocation of DSI would be as follows: DSI on the shares of Newco: DSI of Opco prior to reorg X cost amount of assets transferred to Newco / total cost amount of assets of Opco prior to reorg DSI on the shares of Opco after reorg: DSI of Opco prior to reorg X cost amount of assets retained by Opco / total cost amount of assets of Opco prior to reorg Example 2 [basic example that illustrates split of ISI] In this situation, Opco did not realize any income. ... The formula for calculating ISI (below the Newco level) should be as follows: ISI on the shares of Newco: ISI to Holdco on the shares of Opco (that excludes the DSI of Opco) prior to reorg X ISI to Holdco of entities held by Opco that are transferred over to Newco / total ISI to Holdco of all entities held by Opco prior to reorg ISI on the shares of Opco after reorg: ISI to Holdco on the shares of Opco prior to reorg X ISI to Holdco of entities held by Opco that are retained by Opco / total ISI to Holdco of all entities held by Opco prior to reorg Example 3 [example that shows the interaction of outside ACB and inside ACB] In this scenario, Holdco acquired Opco for $300 a few years ago. ... The formula for calculating ISI (below the Newco level) as reflected in slide #2 should still be valid and the calculation would be as follows: ISI on the shares of Newco: ISI of Opco (that excludes the DSI of Opco) prior to reorg X ISI of entities transferred over to Newco / total ISI of all entities held by Opco prior to reorg ISI on the shares of Opco after reorg: ISI of Opco prior to reorg X ISI of entities retained by Opco / total ISI of all entities held by Opco prior to reorg Example 4 This is the same as Example 3, except that Subco1 has realized DSI of $500 after the acquisition of Opco by Holdco. ...

& 2. The residence of a trust in Canada, or in a particular province, is a question of fact, to be determined based on the unique facts in each case. ...

National CTF Conference November 27 – 29, 2011 Question 24 Please provide CRA's views as to the deductibility of interest on funds borrowed to finance a repayment of capital by a public company, in circumstances where the paid-up capital of the shares exceeds the return of capital, but subsection 84(4.1) applies to recharacterize the return of capital as a dividend. ...

CALU CRA Roundtable – May 2014 Question 2 Update on Folio Project The Income Tax Rulings Directorate has started to update and improve the technical content contained in Interpretation Bulletins through the creation of a new technical tax publication called Income Tax Folios. ...

Reasons: See below. 2010 CTF Conference – November 28, 2010 Flow-through Shares Question 19 Does the CRA consider that Canadian exploration expenses (CEE) can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share under both the current and proposed definitions of "flow-through share" in subsection 66(15)? ...

Position: Yes – but could obtain waiver of Reg 105 withholding in certain circumstances. ...

Please refer to CRA's website: www.cra-arc.gc.ca What's new for Corporation Internet Filing / Mandatory Internet Filing of T2 Returns 2009-031673 Alison Campbell May 1, 2009 ...

As a result, pursuant to subparagraph 2(a) of Article X of the Treaty, the Canadian withholding tax rate is limited to 5% of the gross amount of the dividends provided that firstly, the S Corporation is the beneficial owner of the dividends and owns 10 % or more of the voting stock of the company paying the dividends and secondly, the S Corporation is a "qualifying person" for purposes of Article XXIX A (LOB provision) of the Treaty. ...

During the review period, the CRA continues to administer employee discounts on merchandise in accordance with the administrative policy outlined in Guide T4130, Employers Guide – Taxable Benefits and Allowances, which is currently available on the tax pages of the Canada.ca website. ...

4 May 1992 Roundtable, 9212130 F- Debt Repayment Unedited CRA Tags 18(9.1)   Prepared by:  J. ...