Search - 司法拍卖网 人民法院

2 July 2013 External T.I. 2012-0454251E5- 149(1)(l) – donations to capital fund-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) sale of naming rights Generally, an organization referred to under s. 149(1)(l) will not lose its s. 149(1)(l) exemption for collecting donations from members or from businesses affiliated with its members for use in a capital project that furthers the organization's non-profit purposes, nor will it lose its exemption for maintaining a "wall of honor," naming rights, or similar systems for recognizing such contributions, providing that such recognition has only nominal value. ...

4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans The employees of Corporation A were members of four basic insurance plans respecting health insurance, salary insurance and accidental death and dismemberment insurance available to employees of employers in a particular industry. ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1)-- summary under Paragraph 18(6)(c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c) "because of" causality test What is the requisite degree of linkage referenced by the "because" test in clause (B) of ss.18(6)(c)(i), 18(6)(c)(ii), 212(3.1)(c)(i) and 212(3.1)(c)(ii) (the "Clause B causality tests") between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, so as to engage s. 18(6.1) or 212(3.2)? ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) bequests to both spouse and common law spouse Can s. 70(6) apply to a transfer by a taxpayer both to his or her spouse and a transfer to his or her common law spouse? ...

4 March 2015 External T.I. 2014-0562151E5 F- Frais de psychothérapie – dépense d'entreprise-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose “but for” test applied to determine deductibility/potentially creditable item can instead be expense In the course of a business of offering psychology services, a psychologist incurs psychotherapy fees in order to reduce such therapist's personal reaction to the sessions conducted with clients. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) no s. 20(12) deduction available where only a capital gain A deemed-resident s. 94 trust realized a capital gain and incurred gains tax of $10,000 for U.S. purposes on disposing in the U.S. of marketable securities but, for purposes of the Act, realized capital gains of only $20,000 (with Canadian tax thereon of $2,900) due to the securities' ACB previously having been stepped up under s. 128.1(1)(c). ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y)-- summary under Paragraph 95(2)(m) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(m) Canco has a 51% interest in a partnership ("Partnership") holding all the shares of Forco1 which, in turn, owns all the shares of Forco2. ...

17 July 2013 External T.I. 2012-0473261E5 F- Actif d'impôts futurs / Future income tax assets-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share future (or deferred) income tax asset is not an asset until it becomes receivable, whereupon it may be attributable to active business Is a future income tax asset an asset that is used principally in an active business carried on in Canada for purposes of the "qualified small business corporation share" ("QSBCS") and "small business corporation" ("SBC") definitions? ...

21 November 2014 External T.I. 2014-0536771E5 F- Supplément pour frais médicaux – Revenu modifié-- summary under Cohabiting Spouse or Common-Law Partner Summary Under Tax Topics- Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner surviving spouse is not living separate and apart from deceased spouse at year end Where a "cohabiting spouse or common-law partner" dies during a taxation year, is the income of the deceased spouse included in the computation of the refundable medical expense supplement ("RMES") of the surviving spouse; and is the surviving spouse's income included in the calculation of the RMES in the terminal return of the deceased spouse? ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Subparagraph 39(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(ii) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...