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Conference
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6 - TOSI – Excluded Shares & Related Business
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Unedited CRA Tags 84(2), 120.4(1), 120.4(1.1), 125(7), 248(1) Principal Issues: Comparison of CRA’s response to question 7 of the 2018 STEP CRA Roundtable (2018-074403) and examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults. ... CRA Roundtable Question 10: TOSI – Excluded Shares and Related Business In question 7 of the 2018 CRA Roundtable of the Society of Trust and Estate Practitioners (“STEP”) the following question was asked: “Assume that a corporation has no business income because it derives income from property (possibly rental income from real property where the activities are not sufficient to constitute business income). ... Yet, even if it has been determined – taking into account the assumption made in Question 7 – that the shares of the capital stock of the corporation could not qualify as excluded shares, an amount received from this corporation by a specified individual would nevertheless be an excluded amount in respect of the specified individual. ...
News of Note post
6 July 2021- 11:14pm Adélard Soucy – Quebec Court of Appeal finds that a movable structure for warming a soldering operation was not Class 29 property Email this Content The taxpayer custom-fabricated pieces of heavy specialized equipment at the northern mining site of one of its mining customers. ... …. The respondent's Econox serves primarily … to shelter the respondent's operations from the weather …. ... Adélard Soucy (1975) Inc., 2021 QCCA 1050 under Schedule II – Class 8. ...
Current CRA website
Line 25500 – Prescribed Zones – Ontario
Line 25500 – Prescribed Zones – Ontario Place names followed by numbers are Indian reserves. ... Ontario Table of the prescribed northern or intermediate zones for Ontario Zone A – Prescribed Northern Zones Zone B – Prescribed Intermediate Zones Angling Lake Attawapiskat Attawapiskat 91 Attawapiskat 91A Bearskin Lake Bearskin Lake (reserve) Big Beaver House Big Lake (south of Winisk) Big Trout Lake Big Trout Lake (reserve) Cape Henrietta-Maria Wilderness Area Deer Lake (Northern Ontario) Factory Island 1 Fort Albany Fort Albany 67 Fort Hope Fort Hope 64 Fort Hope, Eabamet P.O. ...
News of Note post
Rivoalen JA stated: [S]ection 2 of the Charter protects the rights of the appellant’s members to practise their beliefs in Atheism and the Minister cannot interfere with the practice of these beliefs …. ... The appellant can continue to carry out its purpose and its activities without charitable registration …. ... Canada (National Revenue), 2019 FCA 296 under Charter. s. 2 and ITA s. 149.1(1) – charitable organization – (a). ...
News of Note post
19 February 2018- 9:19pm RCF IV – Federal Court of Australia finds that gains of U.S. limited partners from sales of an Australian resource company were not Treaty exempt but were not TCP-type gains Email this Content Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them. ... Summaries of Resource Capital Fund IV LP v Commissioner of Taxation [2018] FCA 41 under Treaties – Income Tax Conventions – Art. 3, Art. 13, s. 248(1) – taxable Canadian property – (d), s. 115(1)(a)(ii), s. 9 – capital gain. v. profit – shares, General Concepts – stare decisis, s. 152(1). ...
Technical Interpretation - Internal summary
18 November 2004 Internal T.I. 2004-0083251I7 - Management Fees -- summary under Rectification & Rescission
18 November 2004 Internal T.I. 2004-0083251I7- Management Fees-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission General discussion of the distinction between rectification of mistakes and retroactive tax planning. ...
News of Note post
Sommerfeldt J then considered the exception in ETA s. 191(5), which provides that an individual builder is not required to so self-assess where “after the construction … of the complex … is substantially completed, the complex is used primarily as a place of residence for the individual [or family].” He quoted the conclusions of Hogan J in Coates that: [S]ubsection 191(5) … requires … a simple factual determination as to whether or not the property was used as a family home after it was substantially completed. … [T[he exception cannot be interpreted as requiring that the property have been built only for purely personal reasons. ... The Queen, 2020 TCC 115 under ETA s. 123(1) – builder – (f) and s. 191(5). ...
GST/HST Interpretation
21 January 2021 GST/HST Interpretation 202041 - […] Taxation of First Nation Trust […]
21 January 2021 GST/HST Interpretation 202041- […] Taxation of First Nation Trust […] Unedited CRA Tags ETA Part IX, 123(1), Indian Act: Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 10th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 202041 Dear [Client]: Subject: [GST/HST INTERPRETATION] […] Taxation of First Nation Trust […] Thank you for your letter of [mm/dd/yyyy], concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to professional services supplied to a trust established by […] [a First Nation] […]. ... You asked that the Canada Revenue Agency (CRA) include a trust in the definition of “band-empowered entity” found in GST/HST Technical Information Bulletin B-039, Administrative Policy – Application of the GST/HST to Indians (TIB B-039). ...
GST/HST Ruling
16 August 2022 GST/HST Ruling 225972 - & INTERPRETATION – […][Whether the Product is a zero-rated Basic Grocery item]
16 August 2022 GST/HST Ruling 225972- & INTERPRETATION – […][Whether the Product is a zero-rated Basic Grocery item] Unedited CRA Tags ETA Sch VI, Part III Sec. 1(m) Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... STATEMENT OF FACTS We understand the following: 1. […] (the Company) is a GST/HST registrant holding Business Number [...]. 2. ... Each individual […][item] weighs [#] grams. 4. The Product is sold and shipped to […][vendors] in cases of [#] […][items]. […], the Product is sold to consumers on an individual basis. 5. […], it is our understanding that the […][Product is] not individually packaged. […][The Product is shipped] in a frozen state […] thawed by the store [and kept refrigerated] for resale to customers. […]. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return On this page... ... First year: 10% × $780,000 = $78,000 $78,000 ÷ 2 = $39,000 CCA (half-year rule) Second year: $780,000 − $39,000 = $741,000 (undepreciated capital cost) $741,000 × 10% = $74,100 CCA Third year: $741,000 − $74,100 = $666,900 (undepreciated capital cost) $666,900 × 10% = $66,690 CCA And so on for the following years. ... First year (2016): $9,000 ÷ 9= $1,000 $1,000 ÷ 2= $500 CCA (half-year rule) Second year and following (2017 to 2023): $1,000 CCA per year Last year of amortization period (2024): $1,000 × 1 1/2 = $1,500 CCA. ...