Search - 司法拍卖网 人民法院
Results 1071 - 1080 of 79283 for 司法拍卖网 人民法院
News of Note post
The transitional provision indicated that the reduced rate applied inter alia “to any supply … made on or after January 1, 2008.” ... In any event, ETA s. 133 (which, in approximate terms, deems supplies of property to occur when the agreement for their supply is entered into) deemed the agreements to be supplies of the condos, with D’Arcy J. noting in this regard that “[t]he application of section 133 is also not contingent on the existence of the Condo Units at the time the parties entered into the … Agreements ….” ... The Queen, 2022 TCC 56 under ETA s. 133 and s. 225(1) – A(a). ...
News of Note post
17 November 2021- 10:17pm Lauria – Tax Court of Canada accepts that shares transferred 3 weeks prior to filing the IPO preliminary should be valued at a 40% “marketability” discount to the IPO value Email this Content On April 1, 2006, the taxpayers, who were executives of Gluskin Sheff+Associates Inc. ... In fact, the Appellants just seemed to ignore it, when in my opinion, having regard to their skills in and knowledge of the securities industry from working as executives for a wealth management firm and the multiple other circumstances or red flags that went up … they were clearly aware of the impact of the IPO’s value on their holdings. ... The Queen, 2021 TCC 66 under General Concepts – FMV – shares and s. 152(4)(a)(i). ...
News of Note post
8 August 2021- 10:58pm 4431472 Canada – Federal Court sets aside a CRA decision not to reassess on the basis that it was unclear whether it was a final decision Email this Content A Canadian corporation (“443 Inc”) filed its tax returns on the basis that distributions received by it from a trust were distributions of fee income (the “GAM fees”). ... In explaining the significance of the distinction between these two alternatives, Pamel J had earlier noted the statement in IT-335R2 regarding s. 56(2) that “it is normally the … CRA … practice not to assess the same income twice. ...
News of Note post
20 December 2021- 10:57pm Godcharles – Quebec Court of Appeal applies s. 68 to reallocate between a retirement home’s business operations sold by one vendor and the home sold by the other vendors Email this Content A group of unrelated individuals were the co-owners of a seniors’ residence, which was leased by them to the corporate operator of the residence (“9118”), whose shares they owned in the same proportions as the residence. ... Agence du revenu du Québec, 2021 QCCA 1843 under s. 68(a), s. 69(1)(b)(i), s. 251(1)(c) and General Concepts – FMV – real estate. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 8: Page 9 of the
Line 840 – Tax instalments paid On line 840, report all instalment payments you made for the tax year. ... Line 894 – Refund code If entitled to a refund, enter one of the following codes on line 894: enter " 1 " or leave this line blank if you want the CRA to send you the refund enter " 2 " if you want the CRA to transfer the refund to next year's instalment account enter " 3 " if you want the CRA to apply the refund to another liability (such as an expected debit from a reassessment) or to a different account. ... Line 957 – Tick the yes or no box. Lines 958 and 959 – If you answer no to line 957, provide the first and last names and telephone number of a contact person. ...
News of Note post
Mahadevan J stated: Formula One … expressly held that exclusive possession is not essential – temporary or shared use of space is sufficient, provided business is carried on through that space. … [T]he functions performed by the appellant, through its staff operating from the hotel premises … clearly establishing their control over the day to-day operations of the hotel. ... Mahadevan J went on to state: [T]he appellant’s executives and employees made frequent and regular visits to India to oversee operations and implement the SOSA. … Under Article 5(2)(i) of the DTAA, the relevant consideration is the continuity of business presence in aggregate – not the length of stay of each individual employee. ... No. 9766 of 2025 under Treaties – Income Tax Conventions – Art. 5. ...
Current CRA website
Reporting fees for service external stakeholder working group – What we heard – Summary
Reporting fees for service external stakeholder working group – What we heard – Summary On this page: Background information Working group overview Takeaways Contact us Background information Reporting fees for service (RFS) is the legislated obligation requiring Canadian businesses and organizations to report fees paid for services in prescribed form to the Canada Revenue Agency (CRA). ... They: emphasized that the T4A slip is not the appropriate reporting vehicle for RFS since this slip is typically associated with payroll – this could create confusion and administrative challenges for businesses and organizations thought the current $500 reporting threshold may be too low because it would likely increase the administrative burden without offering added compliance benefits noted a lack of clarity on what constitutes a reportable service, particularly in cases when goods and services are not distinguished on an invoice called for enhanced communication and educational resources to ensure businesses and organizations fully understand their RFS reporting obligations recommended a phased implementation approach focusing on specific sectors first to help businesses and organizations become aware of and comply with the RFS requirement supported the creation of exemptions to alleviate administrative burden based on size and type of business These findings underscore the importance of creating a streamlined, flexible, and accessible reporting process that accommodates the diverse needs of businesses and organizations while advancing the CRA’s goals of addressing the underground economy and promoting tax fairness. ... Contact us For more details on the findings from the working group, you can request a copy of the Reporting fees for service external stakeholder working group – What we heard report by sending an email to ReportingFeesService-DeclarationHonorairesService@cra-arc.gc.ca. ...
Archived CRA website
ARCHIVED – Education Tax Measures – Study Abroad
ARCHIVED – Education Tax Measures – Study Abroad Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... For more details please see our publication RC192, Information for Students – Educational Institutions Outside Canada. 5. ...
Article Summary
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35 -- summary under Clause 149(1)(o.2)(iii)(B)
[fn 18: 2012-0461151E5]. … [T]rade payables not evidenced in writing are not similar to bonds, notes, debentures, or mortgages. … Bonds etc. issued by LP are not issued by (o.2) corp as limited partner (pp. 29:10- In some common-law jurisdictions, a debt obligation issued by a partnership might be considered to be a debt obligation issued by the partnership’s investors…. ... OMERS … denies the existence of any legal relationship between the limited partners and a third party that has entered into a contract with the limited partnership (or, as the court more precisely puts it, a contract between the third party and the general partner acting in its capacity as general partner of the limited partnership). … [S]ection 253.1 provides that, for the purposes of paragraph 149(1)(o.2) and other listed provisions, when a trust or a corporation holds an interest as a member of a partnership and, by operation of law, the liability of the partner as a member of the partnership is limited, the partner is not considered to be carrying on the business or other activity of the partnership solely by virtue of acquiring or holding an interest in the partnership. … The issuing of debt should be viewed as part of the “business” or “activity” of the partnership that would not, as a result of section 253.1, be considered to be carried on by the investment corporation. … Consolidated Mogul … [stated:] [T]he financing function of a mining company is an integral part of its business. … Accordingly … [t]he result of such application is that the issuance of a debt obligation by a limited partnership should not be attributed to its limited partners. Guarantee of LP debt does not engage s. 149(1)(o.2)(iii)(B) (pp. 29:13- 16) [O]n June 26, 2013…the phrase “that had not issued debt obligations” was replaced with “that had not... issued bonds, notes, debentures or similar obligations.”… [A]ccording to … Federated Co-operatives … “similar obligation” is a narrower category than “obligation.” ...
Archived CRA website
ARCHIVED – T4A Slip – Box 048
ARCHIVED – T4A Slip – Box 048 Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... Previously, payments for fees for services were reported in Box 28 – Other income, along with many other types of income. ...