Search - 哈尔滨到北京 公里数

On the facts …, we are of the opinion that the Corporation was entitled to receive the life insurance proceeds in … the year of Individual's death. The capital sum insured … can therefore be considered to be an amount of principal owed to the Corporation … on which the Court awarded interest under article 1619 C.C.Q. ...

(e)(iii) exclusion applied, CRA stated: [T]he wording of the exclusion … allow[s], inter alia, an employee's own vehicle that is used in the course of employment under the conditions set out in that subparagraph, and for which the employee's expenses are not reimbursed by the employee's employer, to be excluded from the definition of automobile …. [T]he exception in subparagraph (e)(iii) … may even apply to a self-employed person who primarily uses the individual’s vehicle at a location described in subparagraphs 6(6)(a)(i) or (ii) …. ...

After finding that the “time the agreement was made” in s. 110(1)(d)(ii)(A) referenced the time of the sending of the Exercise Notice to the Participant, the Directorate went on to state: [T]he fact that the Participants who did not directly or indirectly hold shares in the capital stock of Opco have seen substantially all of their Options expire each year without being able to exercise them, while some of the Participants who directly or indirectly held shares of the capital stock of Opco have been able to exercise substantially all of their Options before they expire, may be an indication that subsection 7(5) would apply …. ... In such a situation, it would be other provisions such as subsections 15(1) or 246(1) that would apply. … To the extent that … some of the Participants received the benefit of the issuance of the Exercise Notices in a capacity other than by virtue of an office or employment, we are of the view that section 7(5) could be invoked. ...

The Directorate responded: [Per] E 2002-0121825 … if the taxpayer provides a written certification from the taxpayer's physician that, in his or her opinion, on the basis of the taxpayer's medical condition, the taxpayer is unable to obtain substantially equivalent medical treatment … the travel expenses would be eligible. … This certificate should state the reasons why the physician is of the opinion that there are no adequate and appropriate medical services in the venue where the patient resides. ...

CRA responded: The Act does not define "land" except for the purposes of subsection 18(2), where subsection 18(3) defines "land" to specifically exclude buildings and other structures …. ... Thus … for the purposes of subsection 70(5.2) … "land" includes not only vacant land, but also land on which other real property such as houses or condos are erected. ...

For example, in Scenario 1, the FX rate is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2, and at Time 2, Can Opco pays a dividend of $120 to Can Holdco. And in Scenario 2, the exchange rates are US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Times 1 and 2, respectively- and at Time 2 Can Opco pays a $100 dividend to Can Holdco. ...

. … Paragraph (b) of that definition provides that, on the disposition of the shares, all or substantially all of the fair market value of the property, described in subparagraph (a)(iv) of the definition, owned by the corporation, is attributable to inter alia property that was used principally in the course of carrying on the business of farming in Canada by a person or partnership described in subparagraph (a)(i) ….... ... Consequently … in order to meet the test set out in paragraph (b) … it is necessary to consider the use of the property throughout the period that the taxpayer was the owner. ...

. … [T]hey are receiving an economic benefit from their employer. Furthermore … this reimbursement is not made in the context of a training program …. ...

CRA stated: [A] valid PLOI election must … include the details indicated on … Pertinent loans or indebtedness ….You may also wish to include a calculation of the change in income of each affected taxation year. ... Therefore … the CRIC would not be required to file an amended corporate tax return…. ...

CRA stated: [A] valid PLOI election must … include the details indicated on … Pertinent loans or indebtedness ….You may also wish to include a calculation of the change in income of each affected taxation year. ... Therefore … the CRIC would not be required to file an amended corporate tax return…. ...