Search - 哈尔滨到北京公里数

Results 1451 - 1460 of 2967 for 哈尔滨到北京公里数

Numerous difficulties remain in applying the FA system to partnerships

(c) of the EP definition refers to property of the FA “all or substantially all of the income from which is … income from an active business.” ... Summaries of Tina Korovilas and Drew Morier, “Non-Corporate Vehicles in the Foreign Affiliate Context,” Canadian Tax Foundation, 2018 Conference Report, 20:1 – 114 under s. 96, s. 104(1), Reg. 5907(11.2)(b), s. 90(1), s. 93.1(2)(a), s. 93.1(2)(d)(i), Reg. 5901(2)(b)(ii), s. 93(1.3), s. 95(1) – excluded property – para. ... (c), s. 95(2)(y), s. 95(2)(z), s. 95(2)(a)(ii)(B)(II), s. 95(2)(a)(ii)(D) and s. 94(1) – exempt foreign trust – (h)(ii)(C)(I). ...

The split income proposals assume a model that is at variance with the reality of long-term family businesses

Under the proposals, all dividends and capital gains — to everybody — will be split income and taxed at the top rate. ... " However, this proposition does not take into account that: The nature of the small business financed by family is that the appropriate arm's-length return is almost impossible to calculate — in many cases, no arm's-length person would finance the operation on any terms. ... Summary of Kevyn Nightingale, “Private Company Income Splitting: Part 2 – Observations, Tax Topics (Wolters Kluwer), No. 2371, 17 August 2017, p. 1 under s. 120.4(1) – split portion- para. ...

CRA considers that a share of the revenues of a mortgage broker paid to a franchisor generally will be subject to GST/HST

Summaries of Excise and GST/HST News, No. 100, November 2016 under ETA, s. 123(1) – financial service – para. ...

CRA clarifies how the equity-contribution component of the equity amount of a trust in determined for thin cap purposes

Summary of 19 August 2016 External T.I. 2015-0585471E5 under s. 18(5) – equity amount – (b). ...

CRA indicates that the upstream loan rules can be used to avoid the debt forgiveness rules

Summaries of 20 March 2017 External T.I. 2014-0545591E5 under s. 90(9) and s. 80(1) – excluded obligation – para. ...

CRA indicates that the distinction between the provision of services and property under the split income rules will be informed by the rationale of the safe harbour exclusions

Summaries of 8 May 2018 CALU Roundtable, Q.6, 2018-0745871C6 under s. 120.4(1) – excluded share – (a)(i) and (c). ...

CRA indicates that having non-contributing children as members of a family stock market partnership is subject to challenge under the old rather than TOSI rules

Summary of 5 October 2018 APFF Roundtable, Q.12 under s. 120.4(1) – split income – s. ...

You are here

Search - 哈尔滨到北京公里数

Filter by Type:

Numerous difficulties remain in applying the FA system to partnerships

The split income proposals assume a model that is at variance with the reality of long-term family businesses

CRA considers that a share of the revenues of a mortgage broker paid to a franchisor generally will be subject to GST/HST

CRA clarifies how the equity-contribution component of the equity amount of a trust in determined for thin cap purposes

CRA indicates that the upstream loan rules can be used to avoid the debt forgiveness rules

CRA indicates that the distinction between the provision of services and property under the split income rules will be informed by the rationale of the safe harbour exclusions

CRA indicates that having non-contributing children as members of a family stock market partnership is subject to challenge under the old rather than TOSI rules

CRA indicates that the 10% of votes and FMV tests for excluded share status can be satisfied on a collective basis

CRA indicates that dividend income flowed through to a preferred beneficiary can be TOSI

CRA indicates that required top-up payments to satisfy the minimum-amount IPP rules do not qualify for income-splitting

Pages

You are here

Search - 哈尔滨到北京 公里数

Filter by Type:

Pages

Search - 哈尔滨到北京公里数