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Current CRA website
Readout: Advisory Committee on the Charitable Sector – November 3 & 4, 2022
Readout: Advisory Committee on the Charitable Sector – November 3 & 4, 2022 November 3, 2022 The Advisory Committee on the Charitable Sector (ACCS) met in Ottawa in person for a two day meeting, held on November 3 and 4, 2022. ...
Current CRA website
Readout: Advisory Committee on the Charitable Sector – June 8 & 9, 2023
Readout: Advisory Committee on the Charitable Sector – June 8 & 9, 2023 The Advisory Committee on the Charitable Sector (ACCS) met in Ottawa in person for a two day meeting, held on June 8 and 9, 2023. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return From: Canada Revenue Agency On this page... Small business deduction Avoidance of the business limit and taxable capital limit Preventing multiplication of the small business deduction Line 400 – Income from active business carried on in Canada Active business income Specified investment business Personal services business Specified corporate income Specified farming or fishing income Specified shareholder How to calculate income from an active business carried on in Canada Specified partnership income Line 405 – Taxable income for the SBD Line 410 – Business limit Line 426 – Reduced business limit Assignment of the business limit under subsection 125(3.2) Line 430 – Small business deduction Small business deduction Corporations that were Canadian-controlled private corporations (CCPCs) throughout the tax year may be able to claim the small business deduction (SBD). ... To calculate the total taxable capital employed in Canada, use the schedule that applies: Schedule 33, Taxable Capital Employed in Canada – Large Corporations Schedule 34, Taxable Capital Employed in Canada – Financial Institutions Schedule 35, Taxable Capital Employed in Canada – Large Insurance Corporations If your taxable capital employed in Canada is more than $10 million, file the appropriate schedule with your return. ...
Current CRA website
Appendix B – Certificate of zero-rated entitlement – Example Image
Appendix B – Certificate of zero-rated entitlement – Example Image Previous page Report a problem or mistake on this page Privacy statement The information you provide through this survey is collected under the authority of the Department of Employment and Social Development Act (DESDA) for the purpose of measuring the performance of Canada.ca and continually improving the website. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – June 8, 2018
Offshore Compliance Advisory Committee – Minutes – June 8, 2018 Friday, June 8, 2018 List of Participants OCAC Members Chairperson Colin Campbell Vice-Chair Kimberley Brooks (by phone) Committee Members Catherine Brown Larry Chapman Daniel Thornton CRA Attendees Assistant Commissioner, International, Large Business and Investigations Branch Ted Gallivan Executive Director, Offshore Compliance Liaison Office Gina Jelmini Coordinator, Offshore Compliance Liaison Office Stephanie Weber Director General, Agency Change and Innovation Directorate Mireille Éthier Director, Accelerated Business Solutions Lab André Patry Manager, Strategic Research and Tax Gap Michelle Gouchie Principal Policy Analyst, Strategic Research and Tax Gap Stephanie Gan Director General, Criminal Investigations Directorate Johanne Charbonneau Director General, Offshore and Aggressive Tax Planning Directorate Sue Murray Corporate Services Officer, Offshore and Aggressive Tax Planning Directorate Amy Siu Manager, Offshore Workload Development Anne Lee 1. ... Next steps / forward agenda, closing remarks and in camera discussion There was a quick recap of the priorities first outlined and noting of additional possible topics for future discussion that emerged during the day such as disclosure of uncertain tax positions, a look at the United States’ Internal Revenue Service provisions that help to scope audits, and the UK regime on limited liability. ...
News of Note post
2 December 2019- 9:55am Zong – Tax Court of Canada finds that mandatory contributions by a dual resident to the UK’s national insurance scheme did not qualify for FTC purposes Email this Content A resident of both Canada and the UK who was employed full-time in the UK for several years was not entitled to claim a foreign tax credit under s. 126(1) for mandatory contributions that he made in 2016 to the UK’s national insurance scheme, on the basis that such contributions were not foreign income “taxes”. ... The Queen, 2019 TCC 270 under s. 126(7) – non-business-income tax and Treaties – Income Tax Conventions – Art. 24. ...
News of Note post
In allowing the Crown’s appeal of 2010 and 2012, Dawson JA stated: … [T]he use of the phrase “directly or indirectly” evidences Parliament’s intent “to capture any and all methods through which a transaction could increase” the fair market value of a TFSA. [T]he Tax Court’s concern about “when or how far into the future an advantage … will be considered as attributable to” abusive transactions did not justify a restrictive interpretation of the definition of advantage. … [W]hile the increase in value in the TFSA in 2010 and 2012 was directly attributable to the performance of the shares held in the TFSA each year, it was indirectly attributable to the swap transactions which increased the number of shares held in the TFSA and their value. ... Canada, 2019 FCA 255 under s. 207.01(1) – advantage – s. (b)(i). ...
4 April 2014- 10:41am Resource Capital – Australian Federal Court of Appeal finds that, in determining whether the principal asset of a mining company is resource property, substantial separate value should not be accorded to the (intangible) mining information Email this Content A year ago, the Australian Federal Court found that if a sale of shares by a non-resident vendor (RCF) of an Australian gold mining company had not been Treaty-exempt, the company should not be considered to have more than 50% of its assets as Australian real property (i.e., its mining rights), so that the gain also would not have been taxable under the Australian equivalent of the taxable Canadian property rules. ... Ct. of Austr.) under General Concepts – fair market value – other and Treaties – Art 4. ...
News of Note post
14 December 2020- 11:04pm Victus Academy – Tax Court of Canada finds that the hockey program provided by a hockey school was (even if a separate supply) an exempt educational service Email this Content A for-profit private school took the position that it was providing separate supplies of exempt academic programming and taxable hockey training to its students, so that it could claim input tax credits for its significant costs of providing the hockey-school aspect of its services (including the fees of contractors who provided the training). ... Regarding the s. 2 exemption, which refers to a “supply made by a school authority … of a service of instructing individuals in a course that is provided primarily for elementary or secondary students,” she found an implication in Sched. ... The s. 3 exemption relevantly refers to a “supply of … services … made by a school authority primarily to elementary or secondary school students during the course of extra-curricular activities organized under the authority and responsibility of the school authority.” ...
News of Note post
21 April 2022- 11:18pm Kufsky – Federal Court of Appeal finds that a taxpayer received dividends for s. 160 purposes because she was estopped from arguing otherwise or because the corporate insolvency did not matter Email this Content A shareholder loan balance that was owing by the taxpayer was eliminated through dividend declarations backdated to the three preceding years and paid by way of set-off. ... Webb JA found that the taxpayer was estopped from now arguing that the amounts that she had treated as dividends in fact were not dividends (so that s. 160 did not apply to their payment)- because the appropriate procedures for the declaration and payment of the amounts as dividends were not followed and because s. 38(3) of the OBCA prohibited the payment of a dividend by an insolvent corporation – on the basis of the principle that: [A] taxpayer who has benefited from having an amount included in his or her income as a dividend in a particular taxation year (and who has not objected to the assessment of tax based on having received this dividend) is estopped from claiming in any subsequent appeal related to the application of section 160 of the Act, that the previous filing position was wrong. ... Canada, 2022 FCA 66 under s. 160(1), General Concepts – FMV – Other, Onus, and Payment and Receipt. ...