Search - 哈尔滨到北京 公里数

CRA responded: Generally … to be a right or thing … the individual would have to be legally entitled to receive the amount at the time of the individual’s death (the right would have to exist) and the value of that right would have to be determinable at that time. … By virtue of paragraph 138.1(1)(f), the taxable income of the related segregated fund trust is deemed for the purposes of subsections 104(6), (13) and (24) to be an amount that has become payable in the year to the beneficiaries under the segregated fund trust and the amount therefor in respect of any particular beneficiary is equal to the amount determined by reference to the terms and conditions of the segregated fund policy. … We understand that, regardless of the method of income allocation used by the insurer, no amount is actually paid or payable to a related segregated fund policyholder in respect of income allocations made by the insurer. ... Consequently, income and capital gains allocated to a related segregated fund policyholder in accordance with the terms of the policy … are not rights or things for the purposes of subsection 70(2) …. ...

(b) of the definition apply – and would the answer change if the services provided by YCo to XCo were performed by an employee working full time on maintenance work for XCo, an employee working 50% of the time as a receptionist for XCo and another employee working 50% of the time doing secretarial work for X Co? CRA responded: The fact that the services rendered to XCo by YCo require the full-time employment of two employees is an indication that the exception in paragraph (b) … may apply since it may be reasonable to consider that XCo would have required six full-time employees if the services had not been rendered by YCo. … In the second situation … we would need to determine how many full-time employees XCo would hire to replace the services provided by YCo. ...

5 March 2021 External T.I. 2017-0713041E5 F- Allocation pour usage d’un véhicule à moteur-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) unreasonably low allowance may be taxable An employer pays a fixed per-kilometre allowance to its employees for their motor vehicle use in the course of employment – except that if the kilometres driven during a particular period exceed a cap, no allowance is paid for the excess kilometers. Is such allowance unreasonable by virtue of s. 6(1)(b)(x), which deems a motor vehicle allowance not to be reasonable where the measurement of the use of the vehicle for the purpose of the allowance is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment [?] CRA responded: In general … the mere presence of a capping policy such as the one at issue here is not sufficient to conclude that an allowance paid to an employee is deemed not to be reasonable by virtue of paragraph 6(1)(b)(x). … An allowance not being deemed to be unreasonable by s. 6(1)(b)(x) does not necessarily mean it is reasonable for purposes of s. 6(1)(b)(vii.1), which generally excludes a reasonable allowance for employment driving from inclusion under s. 6(1)(b). ...

Respecting the deductibility of the “meal” portion of the charges to the trainees, CRA stated: Paragraph 18(1)(h) explicitly precludes the deduction of personal or living expenses of the taxpayer in the calculation of the taxpayer’s business income …. According to [IT-357R2, para. 5] … any portion of a claim by a participant in respect of training expenses which either is personal or is unreasonable in the circumstances is not deductible by virtue of paragraph 18(1)(h) or section 67, respectively. ...

. … Paragraph 87(2)(a) indicates that … Amalco will be a new corporation and will not be a member of the Partnership immediately before the Partnership has ceased to exist. ...

. … According to our analysis … Municipality and City were not agents of the Quebec government, nor were they entities controlled by that government. ...

In addition … it may be possible … to apply subsection 18(12) to a business loss allocated to a partner by the partnership. ...

16 November 2001 Internal T.I. 2001-0095617 F- ACCORD ECRIT RETROACTIF GARDE D'ENFANTS-- summary under Support Amount Summary Under Tax Topics- Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount “agreement” must correspond “to the reality of a situation of shared financial and parental responsibilities and … [be] a valid contract … creating mutual obligations” After finding that a letter signed by the two separated spouses did not constitute an “agreement” for purposes of the “support amount” and “commencement day” definitions, the Directorate went on to state: A written agreement subsequent to an order could, in certain circumstances, be valid for the purposes of applying the terms "commencement day", "support amount" and "child support amount" if such an agreement corresponded to the reality of a situation of shared financial and parental responsibilities and if the agreement was a valid contract between two parties having the effect of creating mutual obligations. ...

It is arguable that the acquisition of the … MRPS is not considered part of the ordinary course of business carried on by [Canco 2], but rather the acquisition may be considered an isolated and special transaction that is not part of a course of conduct that involves repeated dealings of a similar nature. … [I]t is also important to consider whether the arrangement in the current case, at its core, more closely resembles a debt financing arrangement or a capital investment. …[W]e are more inclined to conclude that the arrangement more closely resembles a capital investment. … [Canco 2] is not in the business of lending money to the general public or to any disinterested third parties and the loans it made were limited to its foreign related corporations. All of the proceeds from the issue of the … MRPS were used by Luxco 1 to make loans to … US foreign affiliates for their US operations. … ...

As the term “individual” … exclude[s] a corporation, the registered charity … would not qualify as an RESP subscriber. ...