30 April 2018 Comfort Letter — Foreign spin-off – prescribed distribution
Miscellaneous administrative policy
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Article Summary
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020 -- summary under Investment Limited Partnership
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership Meaning of “principal activity” A person’s “principal activity,” as discussed … in College of Applied Arts … depends on how important a particular activity assists the person in achieving its overall business objectives and goals when compared to its other business activities. ...
News of Note post
23 July 2018- 11:40pm Quinco Financial – Federal Court of Appeal confirms that interest is added as usual to a GAAR assessment – and that taxpayers do not “apply” GAAR Email this Content Webb JA rejected a submission that no interest accrued by virtue of a GAAR reassessment between the balance-due date of a taxation year for which a large capital-loss claim was denied, and the date of the reassessment almost four years later, stating: [T]he requirement that the Minister in GAAR cases must establish that a tax benefit is not consistent with the object, spirit or purpose of the provisions relied upon by the taxpayer cannot justify a finding that any liability for any increased taxes would only arise once that reassessment is issued. However, he also intimated that the Tax Court had gone overboard (in arriving at the same result) by stating “all taxpayers, who are directly subject to GAAR assessments, … are required to consider and apply GAAR” – which seemed to imply that the taxpayer rather than CRA is responsible under s. 245(2) for determining how the transactions’ tax consequences should be rejiggered to produce a reasonable result. ...
Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar
Miscellaneous correspondence
Email this Content Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar ...
26 June 2015- 10:16am CRA considers that an estate gift funded by share redemption proceeds – but not by a dividend – generally will satisfy s. 118.1(5.1)(b) Email this Content S. 118.1(5.1)(b) provides the new rules for charitable donations from a (post-2015) graduated rate estate and in most circumstances requires that the donation must be a gift of (i) property that was acquired by the estate on and as a consequence of the death or (ii) property that is substituted for that property. ...
T Rev B decision
Charles E Riddoch, Appellant, >>and And. >>minister of National Revenue, Respondent., [1978] CTC 2190, 78 DTC 1163
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Current CRA website
Chapter 15 - 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan
Chapter 15- 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan On this page... 15 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan 15.1 8507(1) – Prescribed Compensation 15.2 8507(2) – Additional Compensation in Respect of Qualifying Period 15.3 8507(3) – Qualifying Periods and Periods of Parenting 15.3.1 8507(3)(a) – Qualifying period 15.3.2 8507(3)(b) – Period of parenting 15.4 8507(4) – Cumulative Additional Compensation Fraction 15.5 8507(5) – Additional Compensation Fraction 15.6 8507(6) – Exclusion of Subperiods 15.7 8507(7) – Complete Period of Reduced Pay 15.8 8508 – Salary Deferral Leave Plan 15 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan Section 8507 of the Regulations contains rules that enable DB benefits to be provided, or MP contributions to be made, in respect of a period of disability, a leave of absence, or a period of reduced pay as if it were a regular period of employment without violating the PA limits in subsections 147.1(8) and (9) of the Act. ... Cross references: Pension Adjustment Limits – 147.1(8) Pension Adjustment Limits – Multi-Employer Plans – 147.1(9) Period of Reduced Services – Retroactive Benefits – 8308(4) Period of Reduced Services – Retroactive Contributions – 8308(5) Definition of Eligible Periods of Reduced Pay – 8500(1) Definition of Eligible Periods of Temporary Absence – 8500(1) Definition of Periods of Disability – 8500(1) Additional Compensation in Respect of Qualifying Period – 8507(2) Qualifying Periods – 8507(3) 15.2 8507(2) – Additional Compensation in Respect of Qualifying Period This subsection contains the rules for determining the amount that is prescribed by subsection 8507(1) of the Regulations in respect of a qualifying period of a member in a year with respect to an employer. ... Cross references: Definition of Eligible Periods of Reduced Pay – 8500(1) Definition of Eligible Periods of Temporary Absence – 8500(1) Deemed Allocation of Forfeitures and Surplus – 8500(7) Definition of SMEP – 8510(2) 15.3.2 8507(3)(b) – Period of parenting This is all or part of the period that starts at the time of the birth or adoption of a child and ends 12 months later. ...
16 November 2016 Toronto Centre Canada Revenue Agency & Tax Professionals - International Tax Issues
Miscellaneous correspondence
Specifically, there were three things were identified in that Action plan: the master file, the local file, and – everybody’s favourite – the country-by-country reporting. ... There are other countries – the US in particular – that have not signed on to that. ... I think you’re right – the OECD and many others have said this is a risk-assessment tool – it is not a tool that will identify adjustments. ...
Tax Interpretations Translation
23 June 2014 External T.I. 2014-0528271E5 F - Terrain « adjacent » à la résidence principale -- translation
23 June 2014 External T.I. 2014-0528271E5 F- Terrain « adjacent » à la résidence principale-- translation ...