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

. … If the automobile benefit was conferred on Son…in his capacity of employee of the corporation and Son included the value of the benefit in computing his income from employment…no amount would be included in computing income of his father under subsection 15(1)…. ...

After summarizing it two-step approach to entity classification, CRA stated: The CRA has not established a list of essential features that a foreign Entity must possess to be classified in any of the different categories of recognized Entities …. ...

On this basis, while the exempt surplus of FA3 would be reduced to $25, … Merged FA's opening exempt surplus is $200. ...

Finally, where a life insurance policy was assigned as security to the lender prior to March 21, 2013 and it is then replaced with a new life insurance policy after that date … this fact, in itself, will not jeopardize the grandfathered status…. ...

. … There is ample authority for the proposition that a trial judge is entitled to arrive at his own opinion as to value.” ...

. … The expectations of a knowledgeable and prudent investor should be determined on the assumption that there would be no delay, postponement or default in the payment of dividends, that the dividends would be paid each year at a predetermined fixed or floating rate and that the proceeds to be received by the investor on the disposition of the share are the same amount the corporation received as consideration on the issue of the share. ...

After noting that the contract with the union “must show that the contributions were paid pursuant to a PHSP within the meaning of section 20.01,” CRA stated: [A] contribution to a plan that qualifies as a PHSP could result in a deduction in computing the income from a business of the individual, who is a self-employed business owner, if all the conditions set out in subsection 20.01(1) were also met and to the extent that such an expense was reasonable in the circumstances. ­ ...

. … Situation 2 Similarly, the CRA considers that the balance owing under the hypothec loan assumed by Child in the circumstances constitutes "an amount payable a property acquired"…. ...

Thus … subsections 15(1), 212(2) and paragraph 214(3)(a) would be likely to subject the non-resident to Part XIII tax. ...

However, where after entering into the contract with Canco, USCoinstead subcontracts a portion of the work to a Canadian subsidiary of USCo or an arm's length Canadian company, USCo will not be considered to have a PE in Canada provided such Canadian company is paid an arm's length fee – and similarly, if a US professional firm subcontracts part of its consulting contract with Canco to an arm's length Canadian professional partnership. ...