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
Results 281 - 290 of 78685 for 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
Technical Interpretation - External summary
25 January 2018 External T.I. 2017-0709241E5 - Subsections 125(3.2) & 125(5.1) -- summary under Subsection 125(5.1)
25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit … is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations … exceeds $10 million … [so that] once the taxable capital … reaches $15 million its business limit would be zero,” CRA stated:. ...
Technical Interpretation - Internal summary
6 September 2023 Internal T.I. 2019-0805481I7 - Interaction of 17.1(1) & 247(2) -- summary under Subsection 247(2.1)
6 September 2023 Internal T.I. 2019-0805481I7- Interaction of 17.1(1) & 247(2)-- summary under Subsection 247(2.1) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2.1) there is no conflict in applying both ss. 17.1 and 247(2) to impute interest on a PLOI A non-resident corporation (Parent2) which, through a wholly-owned non-resident subsidiary, was the sole shareholder of a corporation resident in Canada (“CRIC”), received various unsecured loans from the CRIC, which bore interest at a floating rate equal to the prescribed rate under Reg. 4301(b.1), payable not less than annually. ... In short … subsection 247(2), which was broadly worded to embody the arm’s length principle, was meant to apply to all cross-border transactions, arrangements or events, including financial transactions, between non-arm’s length persons or partnerships, unless a specific exclusion applies. [See] … 2017-0691071C6 …. ...
Technical Interpretation - External summary
29 September 2020 External T.I. 2018-0757501E5 F - Crédit pour intérêts sur les prêts étudiants -- summary under Payment & Receipt
29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt capitalization of interest on a novation under Quebec law would constitute its payment A Quebec post-secondary student loan program provided for an initial 12-month “full exemption period” (in which the Quebec government paid the interest charged on the loan by the lender) and a subsequent six-month “partial exemption period” (during which the student borrower was required to pay interest on the loan balance). ... In addressing whether such capitalized interest qualified as being “paid” under a “loan made” under the Quebec financial assistance program so as to generate a credit under s. 118.62, CRA stated: By virtue of the Civil Code of Quebec, there can be payment where there is a handing over of money [(“tradition d’argent”)] between the debtor and the creditor or where there is novation by change of debt. … The mere addition of accrued interest to the principal amount of an original debt is generally not sufficient in itself to constitute a payment of such interest. If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...
Current CRA website
T2 Corporation – Income Tax Guide – Appendices
T2 Corporation – Income Tax Guide – Appendices From: Canada Revenue Agency On this page... ... For more information go to Email notifications from the CRA – Businesses. ... Mailing address You may write to: Sudbury Tax Centre PO Box 20000, STN A Sudbury ON P3A 5C1 CANADA Fax 705-671-3994 Index Active business income – Schedule 7 Amalgamated corporations Final tax year before amalgamation First tax year – Schedule 24 Appeals Associated corporations – Schedules 23 and 49 Authorizing representatives and employees Available-for-use rule Balance-due day Base amount of Part I tax Books and records Business limit – Schedule 23 Business number Canadian film or video production tax credit – Form T1131 Capital cost allowance (CCA) – Schedule 8 Capital gains refund (federal) – Schedule 18 Capital gains refund (provincial or territorial) – Schedule 18 CCA rates and classes Charitable donations – Schedule 2 Control Acquisition of Definition Losses and changes in control Country-by-country reporting Credit unions Allocation in proportion to borrowing – Schedule 17 Deferred income plans – Schedule 15 Digital services Direct deposit Dispositions of capital property – Schedule 6 Dividends – Schedule 3 Paid Received Refund Subject to Part IV tax Earned depletion base – Schedule 12 Election not to be associated – Schedule 28 Eligible dividend General Rate Income Pool (GRIP) Low Rate Income Pool (LRIP) Election to not be a CCPC Excessive dividend designations Exemption from tax under section 149 Federal qualifying environmental trust tax credit Federal qualifying environmental trust tax credit refund Federal tax abatement Filing requirements Acceptable formats Filing deadlines Where to file Who has to file Film or video production services tax credit – Form 1177 Final return (dissolution) Foreign Affiliates (investment in) – Form T1134, Schedule 25 Business income tax credit – Schedule 21 Non-business income tax credit – Schedule 21 Property Tax deductions, addition to taxable income Functional currency General Index of Financial Information (GIFI) Gifts, Ecological – Schedule 2 Gifts of cultural property – Schedule 2 Inactive corporations Information reporting of tax avoidance transactions – Form RC312 Instalment due dates Instalment payments Internet business activities – Schedule 88 International Financial Reporting Standards (IFRS) Investment Corporation deduction Income – Schedule 7 Tax credit – Schedule 31 Tax credit recapture Tax credit refund Journalism labour tax credit Logging tax credit – Schedule 21 Losses Allowable business investment And changes in control Carry-back – Schedule 4 Continuity and application – Schedule 4 Farm Limited partnership Listed personal property Net capital Non-capital Restricted farm Mandatory electronic filing Mandatory electronic filing for tax preparers Manufacturing and processing profits deduction – Schedule 27 NAICS codes Net income (or loss) for income tax purposes – Schedule 1 New corporations – Schedule 24 Non-profit organizations Exempt from tax Information return – Form T1044 Non-resident Corporations Discretionary trust – Schedule 22 Non-arm's length transactions with non-resident persons – Form T106 Ownership – Schedule 19 Payments to – Schedule 29 Part I tax Part II.2 tax Part III.1 Tax – Schedule 55 Part IV tax – Schedule 3 Part IV.1 tax – Schedule 43 Part VI tax – Schedules 38, 39, 42 Part VI.1 tax – Schedules 43, 45 Part VI.1 tax deduction Part VI.2 tax – Schedule 67 Part XIII.1 tax – Schedule 92 Part XIV tax – Schedule 20 Partnerships Information slip T5013 Limiting deferral of corporation tax Patronage dividend deduction – Schedule 16 Payments to non-residents – Schedule 29 Payments to residents – Schedule 14 Penalties Permanent establishment Personal services business Provincial and territorial tax and credits British Columbia Manitoba New Brunswick Newfoundland and Labrador Northwest Territories Nova Scotia Nunavut Ontario Prince Edward Island Saskatchewan Yukon Provincial or territorial Dual income tax rates Foreign tax credits Jurisdiction Tax credits and rebates Tax payable – Schedule 5 Reassessments Reduced business limit Refundable dividend tax on hand (eligible and non-eligible) Refundable portion of Part I tax Related corporations – Schedule 9 Reserves Capital gains Continuity – Schedule 13 Return of fuel charge proceeds to farmers tax credit – Schedule 63 Scientific research and experimental development expenditures – Form T661 Shareholder information – Schedule 50 Short return (T2) Small business deduction Specified investment business Specified partnership income or loss Tax rate (basic) Tax reduction General Tax shelter loss or deduction – Form T5004 Tax withheld at source Taxable income Addition for foreign tax deductions Calculation Used to calculate small business deduction Transactions Non-arm's length – Schedule 44 With shareholders, officers, or employees – Schedule 11 Wind-up of a subsidiary – Schedule 24 Previous page Table of contents Page details Date modified: 2025-04-01 ...
Technical Interpretation - Internal
15 January 2004 Internal T.I. 2003-0026827 - Non-resident & Tuition & Educations credits
15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits Also released under document number 2003-00268270. ... January 15, 2004 ASSESSMENT & COLLECTIONS BRANCH HEADQUARTERS Individual Returns & Payment Processing Income Tax Rulings Directorate Directorate S. ...
Old website (cra-arc.gc.ca)
Example – Instalment base – Wind-ups
Example – Instalment base – Wind-ups Example On July 31, 2016, a subsidiary corporation wound up and dissolved, and all its assets were distributed to its parent corporation. ... Seven instalment payments of $1,000 each ($12,000 ÷ 12) are due up to July 31, 2016. ... Calculate this amount as follows: ($6,000 × 7) ÷ 12 = $3,500. The second instalment base amount of $18,000 is the total of the parent's normal first instalment base amount of $12,000 for its 2016 tax year and the subsidiary's first instalment base amount of $6,000 for its 2016 tax year. ...
Old website (cra-arc.gc.ca)
Example – Instalment base – Transfers or rollovers
Example – Instalment base – Transfers or rollovers Example On October 31, 2015, a corporation (transferor) disposed of all its property, through a section 85 rollover, to another corporation it was not dealing with at arm's length (transferee). ... Four instalment payments of $1,000 each ($12,000 ÷ 12) are due up to October 31, 2015. ... Calculate this amount as follows: ($6,000 × 4) ÷ 12 = $2,000. The second instalment base amount of $18,000 is the total of the transferee's normal first instalment base amount of $12,000 for its 2016 tax year and the transferor's first instalment base amount of $6,000 for its 2016 tax year. ...
Decision summary
Cussens & Ors v Brosnan, ECLI:EU:C:2017:881:Case C-251/16, [2017] BVC 61 -- summary under Subsection 274(4)
The Court stated (at paras 53, 60- 61): …[T]he case-law stemming from the judgment in Halifax does not require it to be established that the accrual of a tax advantage is the only objective of the transactions at issue. … In order to determine the substance and real significance of the leases at issue in the main proceedings, the referring court may, in particular, take account of the purely artificial nature of those transactions and the links of a legal, economic and/or personal nature between the operators at issue …. Such aspects are capable of demonstrating that the accrual of a tax advantage constitutes the essential aim pursued, notwithstanding the possible existence, in addition, of economic objectives …. …[T]he leases … had no commercial reality and were entered into … with the aim of reducing the VAT liability on the sales of immovable property … which they envisaged carrying out subsequently. ...
Decision summary
Non Corp Holdings Corp. v. Canada (Attorney General), 2016 ONSC 2737 -- summary under Rectification & Rescission
Canada (Attorney General), 2016 ONSC 2737-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission date of capital dividend declaration rectified to eliminate Part III tax The corporate applicant intended to distribute the applicable portion of a “capital gain” (likely, goodwill proceeds) from a business sale as a capital dividend. ... Before amending the directors’ resolution nunc pro tunc to change its date to November 1, 2012, Dunphy J stated (at paras. 7, 9): This case is quite unlike… Birch Hill … decided by me…[where] [t]he rectification sought would have materially re-ordered the transaction in ways that nobody had considered at the relevant time. There was a specific intention to allocate specific proceeds of a specific transaction to a specific tax account – the capital dividend account – to achieve a specific tax goal. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Appendices
T2 Corporation – Income Tax Guide – Appendices On this page... Related forms and publications List of federal and provincial or territorial corporate schedules and forms Online services Handling business taxes online Electronic payments For more information What if you need help? ... Non-resident corporation enquiries If you have a question about a non-resident corporation account, go to Businesses – International and non-resident taxes or call: Within Canada and continental United States 1-800-959-5525 Monday to Friday (except holidays) 9 a.m. to 6 p.m. ... Mailing address You may write to: International and Ottawa Tax Services Office Post Office Box 9769, Station T Ottawa ON K1G 3Y4 CANADA Fax 613-952-3845 Index Active business income – Schedule 7 Amalgamated corporations Final tax year before amalgamation First tax year – Schedule 24 Appeals Associated corporations – Schedules 23 and 49 Authorizing representatives and employees Available-for-use rule Balance-due day Bar Code (2D) Base amount of Part I tax Books and records Business limit – Schedule 23 Business number Canadian film or video production tax credit – Form T1131 Capital cost allowance (CCA) – Schedule 8 Capital gains refund (federal and provincial or territorial) – Schedule 18 CCA rates and classes Charitable donations – Schedule 2 Control Acquisition of Definition Losses and changes in control Credit unions Additional deduction Allocation in proportion to borrowing – Schedule 17 Cumulative eligible capital deduction – Schedule 10 Deferred income plans – Schedule 15 Direct deposit – Form RC366 Dispositions of capital property – Schedule 6 Dividends – Schedule 3 Paid Received Refund Subject to Part IV tax Earned depletion base – Schedule 12 Election not to be associated – Schedule 28 Eligible dividend General Rate Income Pool (GRIP) Low Rate Income Pool (LRIP) Election to not be a CCPC Excessive dividend designations Exemption from tax under section 149 Federal qualifying environmental trust tax credit Federal qualifying environmental trust tax credit refund Federal tax abatement Filing requirements Acceptable formats Filing deadlines Where to file Who has to file Film or video production services tax credit refund Final return (dissolution) Foreign Affiliates (investment in) – Form T1134, Schedule 25 Business income tax credit – Schedule 21 Non-business income tax credit – Schedule 21 Property Tax deductions, addition to taxable income Functional currency General Index of Financial Information (GIFI) Gifts, Ecological – Schedule 2 Gifts of cultural property – Schedule 2 Gifts of medicine – Schedule 2 Inactive corporations Income exempt under paragraph 149(1)(t) Instalment due dates Instalment payments Internet business activities – Schedule 88 International Financial Reporting Standards (IFRS) Investment Corporation deduction Income – Schedule 7 Tax credit – Schedule 31 Tax credit recapture Tax credit refund Logging tax credit – Schedule 21 Losses Allowable business investment And changes in control Carry-back – Schedule 4 Continuity and application – Schedule 4 Farm Limited partnership Listed personal property Net capital Non-capital Restricted farm Mandatory Internet filing Mandatory electronic filing for tax preparers Manufacturing and processing profits deduction – Schedule 27 NAICS codes Net income (or loss) for income tax purposes – Schedule 1 New corporations – Schedule 24 Non-profit organizations Exempt from tax Information return – Form T1044 Non-resident Corporations Discretionary trust – Schedule 22 Non-arm's length transactions with non-resident persons – Form T106 Ownership – Schedule 19 Payments to – Schedule 29 Online services Part I tax Part II surtax – Schedule 46 Part III.1 Tax – Schedule 55 Part IV tax – Schedule 3 Part IV.1 tax – Schedule 43 Part VI tax – Schedules 38, 39, 42 Part VI.1 tax – Schedules 43, 45 Part XIII.1 tax – Schedule 92 Part VI.1 tax deduction Part XIV tax – Schedule 20 Partnerships Information slip T5013 Elimination of deferral of corporation income tax Patronage dividend deduction – Schedule 16 Payments to non-residents – Schedule 29 Payments to residents – Schedule 14 Penalties Permanent establishment Personal services business Provincial and territorial tax and credits British Columbia Manitoba New Brunswick Newfoundland and Labrador Northwest Territories Nova Scotia Nunavut Ontario Prince Edward Island Saskatchewan Yukon Provincial or territorial Dual income tax rates Foreign tax credits Jurisdiction Tax credits and rebates Tax payable – Schedule 5 Reassessments Reduced business limit Refundable dividend tax on hand Refundable portion of Part I tax Related corporations – Schedule 9 Reserves Capital gains Continuity – Schedule 13 Scientific research and experimental development expenditures – Form T661 Shareholder information – Schedule 50 Short return (T2) Small business deduction Specified investment business Specified partnership income or loss Tax rate (basic) Tax reduction General Tax shelter loss or deduction – Form T5004 Tax withheld at source Taxable income Addition for foreign tax deductions Calculation Used to calculate small business deduction Transactions Non-arm's length – Schedule 44 With shareholders, officers, or employees – Schedule 11 Wind-up of a subsidiary – Schedule 24 Previous page Table of contents Date modified: 2017-01-30 ...