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
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SKQB decision
Polyco Window Manufacturing Limited v. The Prudential Assurance Company Limited and Berlinex Polymers Inc., Equibuilt Window Systems Inc., K & K Glass Limited, the Minister of National Revenue, Debonair Industries (1987) Limited, Advance Door Systems Limited, Thompson Plastics Limited, 302602 Alberta Limited, C/O A.B.P. Aluminum Building Products, Western Profiles Limited, Moose Jaw Sash & Door Company (1963) Limited and the Director of Labour Standards, [1994] 2 CTC 399
Indeed, Dunlop, in his text Creditor-Debtor Law in Canada (Toronto: Carswell, 1981), stated at page 428 that: ".. ... Harris & Craske (1915), 8 W.W.R. 514, 22 D.L.R. 694 (Sask. C.A.); Randall v. ... Disbursing funds These claims were proved at the hearing: Berlinex $ 91,210.54 Equibuilt $ 91,128.00 K & K Glass $ 61,457.65 Revenue Canada $ 33,108.27 Debonair $ 24,717.00 Advance Door $ 21,145.26 Thompson Plastics $ 18,729.01 302602 Alberta Ltd. $ 11,748.00 Western Profiles $ 11,038.55 Moose Jaw Sash $ 7,438.00 Labour Standards $ 6,000.00 In summary, the $179,500 shall be disbursed as follows: First, to Revenue Canada $ 33,108.27 Second, to The Director of Labour Standards $ 6,000.00 Third, to Advance Door on its assignment date February 25, 1992 $ 21,145.26 Fourth, to the sheriff, the balance for distribu tion pursuant to the Creditors' Relief Act $119,246.47 Funds otherwise payable to Advance shall remain in Court to the credit of the action between Advance and Polyco, until such time as that defended lawsuit is resolved. ...
Current CRA website
HR – Human Resources Group – Annual rates of pay
HR – Human Resources Group – Annual rates of pay On this page Rates of pay tables for levels HR-01 to HR-07 HR Group pay notes Appendix A – Implementation of retroactive and prospective changes to compensation One-Time Allowance Related to the Performance of Regular Duties and responsibilities Implementation Rates of pay for levels HR-01 to HR-07 HR-01 – Annual rates of pay (in dollars) Effective Dates Salary range October 1, 2021 39,677 to 58,789 October 1, 2022 – 1.25% wage adjustment 40,173 to 59,524 October 1, 2022 – 3.5% 41,580 to 61,608 October 1, 2023 – 0.5% pay line adjustment 41,788 to 61,917 October 1, 2023 – 3% 43,042 to 63,775 October 1, 2024 – 0.25% wage adjustment 43,150 to 63,935 October 1, 2024 – 2% 44,013 to 65,214 October 1, 2025 – 2% 44,894 to 66,519 HR-02 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 October 1, 2021 56,748 59,229 61,858 64,619 67,531 70,595 73,133 October 1, 2022 – 1.25% wage adjustment 57,458 59,970 62,632 65,427 68,376 71,478 74,048 October 1, 2022 – 3.5% 59,470 62,069 64,825 67,717 70,770 73,980 76,640 October 1, 2023 – 0.5% pay line adjustment 59,768 62,380 65,150 68,056 71,124 74,350 77,024 October 1, 2023 – 3% 61,562 64,252 67,105 70,098 73,258 76,581 79,335 October 1, 2024 – 0.25% wage adjustment 61,716 64,413 67,273 70,274 73,442 76,773 79,534 October 1, 2024 – 2% 62,951 65,702 68,619 71,680 74,911 78,309 81,125 October 1, 2025 – 2% 64,211 67,017 69,992 73,114 76,410 79,876 82,748 HR-03 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 71,583 74,106 76,727 79,454 82,312 October 1, 2022 – 1.25% wage adjustment 72,478 75,033 77,687 80,448 83,341 October 1, 2022 – 3.5% 75,015 77,660 80,407 83,264 86,258 October 1, 2023 – 0.5% pay line adjustment 75,391 78,049 80,810 83,681 86,690 October 1, 2023 – 3% 77,653 80,391 83,235 86,192 89,291 October 1, 2024 – 0.25% wage adjustment 77,848 80,592 83,444 86,408 89,515 October 1, 2024 – 2% 79,405 82,204 85,113 88,137 91,306 October 1, 2025 – 2% 80,994 83,849 86,816 89,900 93,133 HR-04 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 80,270 83,138 86,122 89,223 92,439 October 1, 2022 – 1.25% wage adjustment 81,274 84,178 87,199 90,339 93,595 October 1, 2022 – 3.5% 84,119 87,125 90,251 93,501 96,871 October 1, 2023 – 0.5% pay line adjustment 84,540 87,561 90,703 93,969 97,356 October 1, 2023 – 3% 87,077 90,188 93,425 96,789 100,277 October 1, 2024 – 0.25% wage adjustment 87,295 90,414 93,659 97,031 100,528 October 1, 2024 – 2% 89,041 92,223 95,533 98,972 102,539 October 1, 2025 – 2% 90,822 94,068 97,444 100,952 104,590 HR-05 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 89,244 92,361 95,713 99,198 102,769 October 1, 2022 – 1.25% wage adjustment 90,360 93,516 96,910 100,438 104,054 October 1, 2022 – 3.5% 93,523 96,790 100,302 103,954 107,696 October 1, 2023 – 0.5% pay line adjustment 93,991 97,274 100,804 104,474 108,235 October 1, 2023 – 3% 96,811 100,193 103,829 107,609 111,483 October 1, 2024 – 0.25% wage adjustment 97,054 100,444 104,089 107,879 111,762 October 1, 2024 – 2% 98,996 102,453 106,171 110,037 113,998 October 1, 2025 – 2% 100,976 104,503 108,295 112,238 116,278 HR-06 – Annual rates of pay (in dollars) Effective dates Step 1 Step 2 Step 3 Step 4 Step 5 October 1, 2021 99,931 103,585 107,384 111,345 115,349 October 1, 2022 – 1.25% wage adjustment 101,181 104,880 108,727 112,737 116,791 October 1, 2022 – 3.5% 104,723 108,551 112,533 116,683 120,879 October 1, 2023 – 0.5% pay line adjustment 105,247 109,094 113,096 117,267 121,484 October 1, 2023 – 3% 108,405 112,367 116,489 120,786 125,129 October 1, 2024 – 0.25% wage adjustment 108,677 112,648 116,781 121,088 125,442 October 1, 2024 – 2% 110,851 114,901 119,117 123,510 127,951 October 1, 2025 – 2% 113,069 117,200 121,500 125,981 130,511 HR-07 – Annual rates of pay (in dollars) Effective dates Salary range October 1, 2021 105,970 to 127,947 October 1, 2022 – 1.25% wage adjustment 107,295 to 129,547 October 1, 2022 – 3.5% 111,051 to 134,082 October 1, 2023 – 0.5% pay line adjustment 111,607 to 134,753 October 1, 2023 – 3% 114,956 to 138,796 October 1, 2024 – 0.25% wage adjustment 115,244 to 139,143 October 1, 2024 – 2% 117,549 to 141,926 October 1, 2025 – 2% 119,900 to 144,765 Rates of pay will be adjusted within one hundred and eighty (180) days from the date of approval. ... Appendix A – Implementation of retroactive and prospective changes to compensation One-Time Allowance Related to the Performance of Regular Duties and responsibilities The Employer will provide a one-time lump-sum payment of two thousand five hundred dollars ($2,500) to incumbents of positions within the HR Group on the date approval of the rates of pay. ...
TCC (summary)
Great-West Life Assurance Company v. The Queen, 2015 TCC 225 -- summary under Payment & Receipt
The Queen, 2015 TCC 225-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt by relieving obligation to pay pharmacist The appellant ("Great-West") provided prescription drug plans to the employees of various employers. ... See summaries under Financial Services and Financial Institutions (GST/HST) Regulations, s. 4(2) and s. 123(1) – financial service – (f.1) and (r.4). ...
Current CRA website
Chapter 9 - 8503(1) & 8503(2) – Defined Benefit Provisions
Chapter 9- 8503(1) & 8503(2) – Defined Benefit Provisions On this page... 9.1 8503(1) – Net Contribution Account 9.2 8503(2) – Permissible Benefits 9.3 8503(2)(a) – Lifetime retirement benefits 9.3.1 8503(2)(a)(i) – Death benefits 9.3.2 8503(2)(a)(ii) – Cost-of-living adjustments 9.3.3 8503(2)(a)(iii) – Ad hoc increases 9.3.4 8503(2)(a)(iv) – Additional lifetime retirement benefits 9.3.5 8503(2)(a)(v) – Early retirement 9.3.6 8503(2)(a)(vi) – Disability benefits 9.3.7 8503(2)(a)(vii) – Optional forms – Increased 9.3.8 8503(2)(a)(viii) – Optional forms – Decreased 9.3.9 8503(2)(a)(ix) – Retirement benefits while remunerated 9.3.10 8503(2)(a)(x) – Adjustments approved by the Minister 9.4 8503(2)(b) – Bridging benefits 9.5 8503(2)(c) – Guarantee period 9.6 8503(2)(d) Post-retirement survivor benefits 9.7 8503(2)(e) – Pre-retirement survivor benefits 9.8 8503(2)(f) – Pre-retirement survivor benefits – Alternative rule 9.9 8503(2)(g) – Pre-retirement survivor benefits – Guarantee period 9.10 8503(2)(h) – Lump sum payments on termination 9.11 8503(2)(i) Commuted value – Pre-retirement death 9.12 8503(2)(j) – Lump sum payment on death 9.13 8503(2)(k) – Additional post-retirement death benefits 9.14 8503(2)(l) – Additional bridging benefits 9.15 8503(2)(l.1) – Survivor bridging benefits 9.16 8503(2)(m) – Commutation of benefits 9.17 8503(2)(n) – Commutation – Beneficiary's benefits 9.18 8503(2.1) – Rule for Commutation of Benefits 9.1 8503(1) – Net Contribution Account Under the Regulations, the net contribution account is a concept, rather than an actual account, which exists in order to ensure that members retain their rights to their own contributions plus amounts transferred in from other plans or provisions, plus interest, to the extent that they have not been used to pay the benefits promised under the plan. ... Cross references: Pre-Retirement Survivor Benefits – Guarantee Period – 8503(2)(g) Lump Sum Payments on Termination – 8503(2)(h) Lump Sum Payments on Death – 8503(2)(j) Commutation of Benefits – 8503(2)(n) Limits Dependent on CPI – 8503(12) Transfer – Lump Sum Benefits on Death – 147.3(7) IC72-13R8, Employees' Pension Plans 9.8 8503(2)(f) – Pre-retirement survivor benefits – Alternative rule The basic difference between paragraphs 8503(2)(e) and 8503(2)(f) of the Regulations is that under paragraph 8503(2)(e) an annual amount is determined. ... Cross references: Transfer – DB to MP, RRSP or RRIF – 147.3(4) Definition of Money Purchase Provision – 8500(1) Conditions for Registration – 8501(1)(e) Determination of Amounts – 8502(j) Rule for Commutation of Benefits – 8503(2.1) Commutation of Lifetime Retirement Benefits – 8503(7) Payment from Account – 8506(1)(f) Commutation of Benefits – 8506(1)(h) Benefits Under Plan Other Than Grandfathered Plans – 8509(9) Prescribed Amount – 8517 Newsletter No. 94-2, Technical Questions and Answers Newsletter No. 92-12, Commutation and Opting Out of a Pension Plan 9.17 8503(2)(n) – Commutation – Beneficiary's benefits Plans may provide that death benefits payable as periodic payments may be commuted. ...
Current CRA website
Offshore Compliance Advisory Committee – Agenda – December 14, 2018
Offshore Compliance Advisory Committee – Agenda – December 14, 2018 Friday, December 14, 2018 8:30 a.m. – 4:30 p.m. ... Deeper dive into programs, operations and projects Sue Murray / Alexandra MacLean / Stephane Bonin 12:00 Lunch 12:45 6. Department of Justice presentation Lynn Lovett / Daniel Bourgeois 13:15 7. ...
Decision summary
Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152 -- summary under Article 12
Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose BLM was a substantial Irish-resident investment company, which started acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) in 2011 and came to own 443 such claims. ... HMRC denied BLM’s refund claim on the basis of Art. 12(5) of that Treaty, which excluded the application of Art. 12 “if it was the main purpose or one of the main purposes of any person concerned with the … assignment … to take advantage of … Article [12].” ... “It was appropriate for the FTT to have had regard to the fact that there were potential purchasers of the SAAD Claim for whom UK WHT would not have been an issue and for whom the UK-Ireland treaty would not have been relevant [e.g., UK purchasers with tax losses] … who were prepared to pay a price higher than 80% of the interest on the SAAD Claim for reasons wholly unconnected to the UK-Ireland treaty” (para. 78). ...
Decision summary
Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152 -- summary under Article 7(1)
Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) accessing Irish-UK treaty dividend-withholding reduction was not abusive given that not a treaty-shopping or conduit transaction BLM was a substantial Irish-resident investment company, which had been acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) since 2011. ... HMRC denied BLM’s refund claim on the basis of Art. 12(5) of that Treaty, which excluded the application of Art. 12 “if it was the main purpose or one of the main purposes of any person concerned with the … assignment … to take advantage of … Article [12].” ... “It was appropriate for the FTT to have had regard to the fact that there were potential purchasers of the SAAD Claim for whom UK WHT would not have been an issue and for whom the UK-Ireland treaty would not have been relevant [e.g., UK purchasers with tax losses] … who were prepared to pay a price higher than 80% of the interest on the SAAD Claim for reasons wholly unconnected to the UK-Ireland treaty” (para. 78). ...
Technical Interpretation - External
4 December 1991 External T.I. 9117325 F - SR & ED "Related to a Business" & ITC
The taxpayer can direct that the funds be used at the Centre for: A. ... Of particular concern was the requirement in subsection 37(1)(a) of the Act that; "... the taxpayer is entitled to exploit the results of such scientific research and experimental development... ... A Payer will be entitled to deduct from its income a contribution made in the year to a University pursuant to clause 37(1)(a)(ii)(B) of the Act, provided that the following conditions are met: a) the Payer carries on business in Canada in the taxation year; b) the funds are to be used by the University for SR&ED carried on in Canada; c) the SR&ED activity carried on by the University is related to the business of the Payer in the year the expenditure is made; d) the Payer completes and files Form T661, "Claim for Scientific Research and Experimental Development Expenditures"; and e) the Payer is entitled to exploit the results of the SR&ED. ...
TCC (summary)
Merchant v. The Queen, 2010 TCC 467 -- summary under Payment & Receipt
The Queen, 2010 TCC 467-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt set-off of debt constituted payment thereof The shareholder of a Canadian company (“Merchant 2000”) lent U.S. $650,000 to a wholly-owned U.S. subsidiary (“Merchant U.S.”) of Merchant 2000, and subsequently transferred that receivable to Merchant 2000 in exchange for a receivable from Merchant 2000 of $650,000. ... (See for example: Armstrong … 88 D.T.C. 1015 ….) ...
Technical Interpretation - External summary
15 January 2021 External T.I. 2020-0847781E5 - CEWS - remuneration / SSUC - rémunération -- summary under Eligible Employee
Q.2 … The 14 day remuneration condition should be examined based on whether remuneration was paid in respect of a qualifying period and not on the remuneration that was actually paid during a qualifying period. We have provided some additional guidance in question 17-6 …. Q.3 … Although the value of a non-cash taxable benefit is received by the employee because of employment, the value of such benefit is not eligible remuneration paid to an eligible employee for purposes of computing the wage subsidy. Therefore … remuneration for the purpose of the definition of an “eligible employee” … would not necessarily be the same as “eligible remuneration” paid to an eligible employee for purposes of the calculation of the CEWS …. ...