Search - 哈尔滨到北京 公里数

[R]ulings relating to paragraph 20(1)(c)… have been issued in respect of interest on debt, the terms of which included a mandatory conversion feature… [where] the triggering events … were considered to be remote …. ...

18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6- 2015 STEP–Q11-Subsection 118.1(5.1)-sub property-- summary under Subsection 118.1(5.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(5.1) share redemption proceeds – but not by a dividend – are substituted property Amended s. 118.1(5.1) require that a donation be a gift of "property that was acquired by the estate on and as a consequence of the death" or "property that was substituted for that property. ...

. … 2012-0456221R3 is therefore still valid … ...

However, the Directorate preferred the double inclusion alternative: [T]he better view … is that the dividend income and FAPI inclusion are not the same amount … [T]he dividend income is a cash distribution on the shares of S Corporation while the FAPI is a notional allocation of the income of S Corporation deemed to be FAPI on its shares of S Corporation … [so that] the dividend income and FAPI are separate amounts of a different nature … [which] would preclude the application of subsection 248(28). ...

. … Our comments would be the same … if the Corporation had been a large corporation. ...

. … [I]t would seem that the requirements … respecting a BIL appear to be satisfied. ...

CRA responded: Due to the expression “except such portion that is deductible by the EPSP under subsection 20(11) of the Act … as it appears in paragraph 144(8.1)(b) … an employee beneficiary of an EPSP is, effectively, restricted to a foreign tax credit of no more than 15% of the foreign non-business income (other than income from real or immovable property) allocated to them by the EPSP. ...

Consequently … subsection 146(12) would be applicable [here]. … While it may be appropriate for the issuer to use the services of an independent valuator to determine the FMV, this is not specifically required under the Act. ...

There is no provision … that allows for a different calculation … in this situation. ...

CRA indicated that on the disposition by the children to Newco for $0.5M of their common shares of Holdco acquired for $0.5M, the aggregate ACB to them of such shares would not have been reduced pursuant to s. 84.1(2)(a.1)(ii) (before any GAAR application), stating: [N]o part of the aggregate ACB to the children of the common shares of the capital stock of Holdco would be attributable to the capital gains deduction claimed by A … on the crystallization transactions … [given] that, by the application of paragraph 85(1)(g), the entire amount of the capital gain realized by A and in respect of which he would have claimed a capital gains deduction pursuant to section 110.6 would have been attributed to the preferred shares of the capital stock of Holdco. ...