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 351 - 360 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
News of Note post
14 February 2022- 11:01pm Lussier – Court of Quebec finds no taxable benefit in an insurance company employee attending a conference for insurance brokers in Cancun Email this Content The taxpayer, was designated by his employer (“BMO,” an insurance company) to attend a one-week conference for insurance brokers and financial advisors whom one of BMO’s managing general agents had identified as top “performers.” ... In reversing the ARQ assessment to include 62.5% of the cost of the trip in the taxpayer’s income as a taxable benefit, Pilon JCQ stated: The recreational activities were an opportunity to create or maintain relationships with advisors and brokers. … … [T]he ARQ's … approach is somewhat penalizing and unfair to Mr. ... His employer did not give him the choice to participate in a trip, on which he went alone, and where he was expected to work and develop business, which he did, both during business hours and beyond. … [T]he ARQ's position stems either from a misunderstanding of what constitutes the steps required for business development where there is a legitimate growth objective, or from a desire to dictate to a business what its business model should be and how to achieve it. ...
Technical Interpretation - Internal summary
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1) -- summary under Paragraph 85(1)(e.2)
15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Paragraph 85(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e.2) significant FMV shortfall suggested that a benefit was desired to be conferred Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... In finding that s. 85(1)(e.2) likely was applicable unless the TSO chose to respect a price-adjustment clause, the Directorate stated: [I]t is clear that the result of the transaction was that Madame conferred a benefit on Monsieur. … [Furthermore] it seems reasonable … to conclude that Madame desired to confer a benefit on Monsieur since, as sole director of the Corporation, it was she who chose to set the redemption value of the Class D shares at an amount lower than the FMV of the Class A shares transferred in consideration. ...
FCA (summary)
Canadian Forest Navigation Co. Ltd. v. Canada, 2017 FCA 39 -- summary under Rectification & Rescission
Canada, 2017 FCA 39-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission foreign rectification order not dispositive The taxpayer’s Barbados and Cyprus subsidiaries paid amounts to the taxpayer in 2004, 2005 and 2006 as dividends and then, following CRA proposals to assess the dividends, obtained rectification orders from the applicable Barbados and Cyprus courts declaring that the amounts instead were loans to it (or otherwise gave rise to indebtedness). ... Moreover, since these foreign orders involve the appellant and its Foreign Affiliates and not the Minister, a third-party to the foreign proceedings, there is nothing to enforce against the Minister; homologation is therefore a non-issue. … However, Boivin JA further stated (at paras 19-20): I cannot agree … that pursuant to article 2822 C.c.Q. these foreign orders are dispositive and that the Minister has no choice under the ITA but to accept the dividends are actually loans because the orders from Barbados and Cyprus say so. ... These determinations are for the Tax Court judge to make, with a full evidentiary record at his or her disposal. … On this basis, he concluded that Lamarre ACJ should not have answered the Rule 58 question, and set aside her judgment and dismissed the Rule 58 motion before the Tax Court. ...
Miscellaneous severed letter
7 November 1991 Income Tax Severed Letter - Ontario R & D Superallowance and the Quebec R & D Tax Credit
7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...
SCC (summary)
Jean Coutu Group (PJC) Inc. v. Canada (Attorney General), 2016 SCC 55, [2016] 2 SCR 670 -- summary under Rectification & Rescission
Canada (Attorney General), 2016 SCC 55, [2016] 2 S.C.R. 670-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification must give effect to common intention at time The taxpayer (“PJC Canada”), a Quebec corporation, implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. subsidiary (“PJC USA”), that overlooked foreign accrual property income considerations – so that interest generated to PJC USA on a loan that it made back to PJC Canada was included in PJC Canada’s income. ... In the AES case, the mistake consisted of a miscalculation in the adjusted cost base (“ACB”) of the transferred shares ― the procedure agreed to by the parties required the issuance and delivery of a note for an amount precisely equal to the shares’ ACB. ... [T]here is a fundamental difference between a contract under which one of a party’s prestations ― necessary for obtaining the intended tax result ― is to issue and deliver a note in an objectively calculable amount equal to the ACB of transferred shares, and a contract under which there is no obligation addressing FAPI, and no prestations agreed on that would prevent its fiscal consequences. …. ...
Decision summary
Barker v Baxendale Walker Solicitors (a firm) & Anor, [2017] EWCA Civ 2056 -- summary under Negligence, Fiduciary Duty and Fault
Barker v Baxendale Walker Solicitors (a firm) & Anor, [2017] EWCA Civ 2056-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault tax solicitor was negligent in not advising of the risk of an alternative interpretation Mr Baxendale-Walker, the sole equity partner in a law firm specializing in advising on tax-avoidance schemes, charged the taxpayer (Mr Barker) a fee of £2.4 million in advising on a scheme which Mr Barker implemented with a view to avoiding capital gains tax and inheritance tax respecting his shares of a private company. ... Turning to the negligence issue and in setting the stage, Asplin LJ stated (at paras 59 and 61): …The question is whether in the light of all the circumstances no reasonably competent solicitor in the position of the Respondents would have failed to give the specific warning that there was a significant risk that the EBT arrangement would fail to be tax effective because of the post-death exclusion construction. … …[I]t is perfectly possible to be correct about the construction of a provision or, at least, not negligent in that regard, but nevertheless to be under a duty to point out the risks involved and to have been negligent in not having done so …. In allowing the appeal, Asplin LJ found (at para 71): … [T]here was a significant risk that the … arrangement would not work as a result of the post-death exclusion construction which was centrally important to its structure and the likelihood that the promised tax advantages would be delivered. ...
Current CRA website
Line 12906 – Taxable FHSA income – other
Line 12906 – Taxable FHSA income – other Other taxable first home savings account (FHSA) income includes the following: the amount of taxable distributions that you received in the year as a beneficiary upon the death of an FHSA holder the fair market value of any property in the FHSA that was used as security for a loan any property that remains in the deceased holder’s FHSA at the end of the exempt period you are entitled to as a beneficiary Enter the amount from box 24 and box 28 of all T4FHSA slips. ... Forms and publications Income tax package T4FHSA, First Home Savings Account Statement Related topics Line 12905 – Taxable first home savings account (FHSA) income Line 20805 – FHSA deduction Line 23200 – Other deductions Death and FHSAs Page details Date modified: 2025-01-21 ...
Old website (cra-arc.gc.ca)
Privacy Impact Assessment (PIA) summary – Personnel Security Screening - Reliability Status + - Security and Internal Affairs Directorate, Finance and Administration Branch
Summary of the project / initiative / change Personnel Security Screening plays a vital role within the Canada Revenue Agency’s (CRA) security program by ascertaining that all employees are appropriately screened based on the access to information and CRA premises required for the performance of their duties. ... As such, in addition to the current reliability status, the CRA’s Security and Internal Affairs Directorate is putting improvements into place through the development of a new level of security screening, Reliability Status +. ... A valid Reliability Status would be a pre-requisite to Reliability Status +. ...
Technical Interpretation - Internal
21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback Surplus & PAS election
21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (
) if the corporation (
) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (
) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (
) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...
Miscellaneous severed letter
7 January 1992 Income Tax Severed Letter 9134185 - Maintenance payments — adult child — third parties
7 January 1992 Income Tax Severed Letter 9134185- Maintenance payments — adult child — third parties Unedited CRA Tags 60(b), 60(c), 60.1(c), 60.1(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Subject: MAINTENANCE PAYMENTS ADULT CHILD THIRD PARTIES Section(s): 60(b), 60(c), 60.1(c), 60.1(1)] January 7, 1992 Appeals Branch Business and General Appeals & Referrals Division Division K. ...