Search - 司法拍卖网 人民法院

4 March 2015 External T.I. 2014-0562151E5 F- Frais de psychothérapie – dépense d'entreprise-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential choice between claiming therapy expense and credit After finding that psychotherapy expenses potentially could be deducted in computing income of a professional practice, CRA stated: The fact that psychotherapy fees could give rise to a credit under the Act does not preclude their deduction in the computation of income from your business. ...

2013 Ruling 2013-0475701R3- MIC deemed interest & participating debt interest-- summary under Participating debt interest Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest applies to dividends deemed to be interest The Corporation, a "mortgage investment corporation" under s. 130.1(6), pays dividends which take into account, inter alia, its income and financial conditions. ...

17 December 2013 External T.I. 2013-0510371E5 F- MCIA / CEC-- summary under Subsection 24(1) Summary Under Tax Topics- Income Tax Act- Section 24- Subsection 24(1) fmv reduction of eligible capital property to nil does not trigger loss if business still carried on A taxpayer acquired franchise rights which subsequently became worthless as a result of the bankruptcy of the franchisor. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

5 March 2015 External T.I. 2014-0553241E5 F- Bornes de recharge – avantage imposable-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no benefit from free car-charging station An employer installs a charging station for electric vehicles at the workplace. ...

7 April 2015 External T.I. 2014-0552731E5 F- Apportez vos appareils personnels / BYOD-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) monthly payments re employee cell phone costs were allowances given no detailed receipts required Employees, who are required to use cell phones in the performance of their duties and to have their cell phone contracts approved by the employer, but bear the monthly costs of the contracts personally. ...

10 October 2014 APFF Roundtable Q. 4, 2014-0534831C6 F- 2014 APFF Roundtable, Q. 4- Late-filed 86.1 election & 220(3.5) penalty-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) general principles applied to relief of s. 86.1 late-election penalties Is the making of a late election generally accepted without application of the penalty of $100 per month if the absence of a timely election is attributable solely to ignorance of the availability of the election or of the occurrence of an eligible distribution? ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain and distributed the gain to its members. ...

11 October 2013 Roundtable, 2013-0499671C6 F- Actif d'impôts futurs / Future income tax assets-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (c)- Subparagraph (c)(i) future income tax asset is not an asset/tax receivable can be used in an active business Is a future income tax asset an asset used in an active business for the purposes of the definition of QSBC definition? ...