Search - 哈尔滨到北京 公里数

CRA responded: [B]ased on … 2003-0006305 … and the rights, privileges, conditions and restrictions attaching to the Class B Opco shares (and taking into account in particular that the right to dividends of such Class B shares would be subject to the discretion of the board of directors and that such shares would not give rise to the right to share in the remainder of Opco's assets in the event of liquidation), it is possible that the safe income on hand realized by Opco from the time of the issuance of the Class B Opco shares may be fully allocated to the Class A shares of the capital stock of Opco. This is the position … in … 2002-0158885. ...

CCRA responded: … Firm B, cannot carry on mutual fund sales activities because this firm is not registered in group savings but only in life and health insurance. ... X as stated in Income Tax Technical News No. 22. … Mr. X cannot represent Firm A without being remunerated for the services he renders to that firm. ... X must be assessed in a manner that is reasonable in the circumstances. … … [A]n amount of commissions received by Firm A could be allocated to Firm B as compensation for services rendered by Firm B to Firm A such as, for example, the use of Firm B's client network. ...

CRA responded: In … IT-99R5 … the CRA confirms that legal costs incurred to enforce pre-existing rights to interim or permanent support amounts are deductible. ... As a result of … Gallien v. The Queen … 2000 DTC 2514 … legal costs incurred to obtain spousal support pursuant to the Divorce Act, or under provincial legislation in the case of a separation agreement, are also deductible. However, in the case of common-law spouses, the legal costs incurred to negotiate either a … cohabitation contract or a separation agreement are for the establishment and negotiation of an entitlement to support. ...

8 February 2011 External T.I. 2011-0392401E5 F- Crédit d'impôt pour frais médicaux-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) expenses of Quebec massage therapists were ineligible In indicating that expenses paid to Quebec massage therapists were ineligible for the credit, CRA stated: It is therefore necessary to determine whether the applicable provincial legislation … includes massage therapists with medical practitioners which, according to our understanding of that legislation, would not appear to be the case. For the same reason … Chevalier … 2008 TCC 11 … concluded that the fees paid for the services of a naturopathic doctor and an osteopathic practitioner did not qualify for the medical expense tax credit. ...

Regarding when the amount of the credit reduced the ACB of the eligible investments pursuant to s. 53(2)(k), CRA stated: According to the CRA's longstanding position, a tax credit or reduction in the calculation of tax- which is not applied to reduce instalments payable by the taxpayer … is considered to have been received, where all the conditions for obtaining it have been satisfied, at the earliest of the following times: when it reduces the tax payable for a taxation year; at the time it is paid if it allows for or increases a tax refund. In view of the foregoing, where … a qualified investor attaches the prescribed Documents to the tax return that must be filed for a taxation year … in order to claim an amount in respect of the CSEQ, and the amount of the tax credit is less than the balance of tax payable for the year, the CRA is of the view that the CSEQ is received or is entitled to be received on the date of filing of the tax return. … … [T]he qualified investor will be entitled to receive the unused portion of the CSEQ … when the qualified investor files a carryover request, on the date the carryover request is filed. ...

. … Thus, the CRA considers that it is not possible to permit a member of a partnership to directly claim capital cost allowance for an eligible non-residential building, as this would be contrary to the rules respecting the computation of a partnership's income …. … [W]hen a partnership files a T5013 for its fiscal year, it must attach a letter indicating the election under ITR subsection 1101(5b.1). ...

CRA stated: [U]nder paragraph 5907(11.2)(a) … if an FA is resident in a country with which Canada has a treaty but for the purposes of that treaty the FA is not considered to be resident of that country, it will be deemed not to be a resident of the designated treaty country for the purposes of section 5907 …. … As stated in paragraph 15 of Interpretation Bulletin IT-391R, a company is generally resident in the country in which its central management and control is exercised. ...

. … Finally … Ahmad … held that pre-judgment interest was not taxable because no amount was owed to the taxpayer before the judgment was rendered. ...

24 January 2005 External T.I. 2004-0099471E5 F- Convention de retraite pour un actionnaire-employé-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement a significant reduction in bonus or salary matched by an RCA contribution likely suggests it instead is an SDA After noting that contributions by a corporation to an RCA would not be deductible in computing its income where the contributions related to services rendered by a shareholder-employee while self-employed and before the corporation’s incorporation, or to the extent that s. 67 applied, CRA turned to the question whether there would be an SDA if the corporation regularly reduced bonuses to a shareholder-employee by the amount of related contributions to the employee RCA for its employees, and stated: Where a plan or arrangement can qualify as both an RCA and an SDA, it will be treated as an SDA …. … [I]t can be assumed that, except in special circumstances, where a portion of an employee's salary or wages is deferred under an agreement, one of the main purposes is to defer the payment of taxes. … [W]here a significant portion of the salary or bonus to which a shareholder-employee is entitled for services rendered is reduced so as to be contributed to an RCA instead, the existence of the RCA could be questioned since the contribution made by the employer may not relate to benefits that are receivable at retirement. ...

11 October 2019 APFF Roundtable Q. 6, 2019-0812651C6 F- CDA and wind-up of a subsidiary-- summary under Paragraph 87(2)(z.1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(z.1) IT-126R2 applicable in determining when CDA of sub is added to parent’s CDA Holdco, which has a calendar taxation year-end, commences the winding-up of its wholly-owned subsidiary (Opco – which has a June 30 taxation year-end) on March 31, 2018 with an authorizing resolution, and the Opco assets and liabilities are distributed and assumed on that date. ... CRA responded: [In] IT-126R2, the CRA states that it considers that where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. … … The determination of when a corporation is wound up for the purposes of subsections 88(1) and 88(2) requires consideration of all facts and circumstances relevant to a particular situation. ...