Search - 哈尔滨到北京 公里数

The predominant nature of the service … is preparatory in nature to the … potential provision of a financial service, that is, the lending …. ... Summaries of 2 May 2019 GST/HST Ruling 150998 under ETA s. 123(1) – financial service – para. ...

CRA accepted the representations of the couple that their decision to sell out was the result of an unexpectedly successful fertility treatment, producing multiple children (who would not all fit into the condo), stating that the “CRA views the birth of the Assignors’ […][multiple children] as an unforeseen event, given the highly unlikelihood of it occurring given their ages, past fertility treatment results as well as the fertility doctor’s views” – their sale of their contract was exempt. CRA on the GST side is bolder – their income tax siblings likely would not give a ruling like this. ... Summary of 3 December 2021 GST/HST Ruling 193347r under ETA s. 123(1) – builder – para. ...

Accordingly, the branch “earnings” were to be determined under the income tax law of the designated treaty county (under (a)(ii) of the “earnings” definition in Reg. 5907(1)), or under modified Canadian tax rules (under (a)(iii) of that definition), as the case may be – and not under Singapore tax law (under (a)(i).) ... Summary of 24 August 2016 External T.I. 2015-0592921E5 under Reg. 5907(1) – earnings – (a)(i). ...

Summary of 24 January 2018 Ruling 156434 under ETA s. 123(1) – financial service – para. (d) and s. 123(1) – debt security. ...

30 September 2018- 11:54pm Alta Energy may inform the Canadian interpretation of the MLI Email this Content In Alta Energy, Hogan J found that the reference in the preamble to the Canada-Luxembourg Treaty to the prevention or reduction of double taxation was too vague to be indicative of the rationale of the specific Treaty Articles relied upon by the taxpayer – and also found in a GAAR context that Treaty-shopping was not contrary to the object and spirit of the Treaty. ... Kandev, “Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg,” Tax Management International Journal, 14 September 2018, p. 572 under Treaties – MLI – Art. 6. ...

Summary of 23 December 2024 Management Proxy Circular of Lithium Americas under Public Transactions – Other – Continuances/ Migrations and summary of 6 February 2025 Management Proxy Circular of Almonty Industries Inc. under Other – Continuances/Migrations. ...

The “purpose of the [foreign affiliate dumping] rules is to deter foreign multi-nationals from … stuffing non-Canadian operating companies under Canada,” which is remote from the situation of non-resident controlled PE funds buying and continuing to operate a Canadian company. ... Summaries of Peter Lee and Paul Stepak, “PE Investments in Canadian Companies” draft 2017 CTF Annual Conference paper under Treaties – Income Tax Conventions – Art. 10, s. 95(2)(b)(i)(B), s. 18(5) – equity amount – (a)(iii), s. 212.3(1)(b), s. 88(1)(c)(vi)(B)(II), s. 212.3(18)(a)(ii)(B), s. 212.3(16)(b), s. 7(1)(b), s. 6(1)(a), s. 256(9) and s. 110(1)(d)(ii)(A). ...

Summaries of John Tobin, “Infrastructure and P3 Projects,” 2017 Conference Report (Canadian Tax Foundation), 10:1-31 under ETA, s. 168(3)(c), ITA s. 9 – nature of income, s. 13(27)(b), Reg. 3100(1)(b), s. 96(2.2)(d), s. 237.1(1) – tax shelter – para. (b), s. 248(1) – taxable Canadian property- para. (d). s. 18(7) and s. 20(1)(c). ...

., related by blood), stated that if in the alternative management scenarios posed “a source individual in respect of Jeanne is actively engaged on a regular basis in the activities of Trust related to earning income from the business, then the portion of the Distribution related to the Interest would come, directly or indirectly, from a related business in respect of Jeanne” – so that, subject to the next point, Jeanne would have been subject to TOSI on the distributed interest” (apparently even in the child as stock broker scenario). However, even in the business income scenario, the distributed interest income would be excluded under s. 120.4(1.1)(c)(ii) because “the amount would have been an excluded amount in respect of an individual- Jean – who was, immediately before his death, Jeanne's spouse … if the amount were included in computing Jean's income for his last taxation year” (i.e., any such business would have been carried on by Jean himself rather than by a source individual). ... Summaries of 5 October 2018 APFF Financial Strategies and Instruments Roundtable, Q.3 under s. 120.4(1) – split income – (e)(ii)(C), related business – (a)(ii) and s. 120.4(1.1)(c)(ii). ...

Summaries of S3-F10-C3 “Advantages – RRSPs, RRIFs and TFSAs” under 207.01(1) – advantage – (a), (a)(ii), (a)(v), (b)(i), (b)(ii), swap transaction, registered plan swap and s. 207.05(2). ...