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

However, as CRA does not take into account interest relating to acquisitions by a partnership of FA shares for 93.1(2)(d)(i) limit purposes, the s. 113(1) deduction of Canco is $1,000 rather than $700 – so that in computing its taxable income, Canco would have a loss of $300 (i.e., partnership income of $700, minus a s. 113(1)(a) deduction of $1,000). ...

After first assuming that there was no event causing a deemed year end, CRA indicated that under s. 249(1)(b) and 249(5), the taxation year for a graduated rate estate is based on the period for which the accounts are normally made up, which would end with the final distribution date – so that the return due date is 90 days after the final distribution. ...

. … [I]t is our view that the requirements of paragraph 108(2)(a) have been satisfied. ...

In effectively answering “$100,000,” CRA stated: [T]he word "consideration" must, for the purposes of subsection 148(7), receive the broad meaning generally accorded to it in the jurisprudence … [so that where] on a share redemption, the redemption price paid by a corporation is an interest in a life insurance policy that the corporation transfers to the shareholder, the CRA is of the view that the shareholder gave consideration (the redeemed shares) to the corporation for the interest thus transferred. ...

After discussing the s. 214(16)(b) designation, CRA stated: [B]y virtue of the application of paragraph 214(16)(a) and any designation under paragraph 214(16)(b), the non-resident parent could therefore file, no later than two years after the end of each calendar year in which overpayments were made to the Receiver General, a Form NR7-R to recover these amounts, unless these amounts are applied … against amounts owing to or about to become due to Her Majesty in Right of Canada. ...

In its annual return it recognizes that by virtue of s. 18(4) the interest is non-deductible and is deemed to be a dividend – and with the Treaty-reduced rate of withholding being less that the rate at which Part XIII tax actually was withheld. ...

. … At the request of the APFF, the situation described in the statement of the question and the response of the CRA will be brought to the attention of that Department [of Finance]. ...

(c)(ii)(D) – except that by virtue of s. (e)(i), the distribution would be an excluded amount if it was not derived directly or indirectly from a related business in respect of Jocelyne. ...

It follows that … the exception provided for in subsection 74.5(2) could not apply. ...

. … In response to the expressed concern where a mutual fund is invested in a significant number of countries and the burden of allocating the respective information may be burdensome to the taxpayer, the CRA will revise its administrative position and request taxpayers to provide an amended tax slip that correctly reflects the federal foreign tax credit amounts claimed. ...