Search - 哈尔滨到北京 公里数

However a textual, contextual and purposive interpretation of subparagraph 55(5)(e)(i) does not allow us to override its wording …. ...

(e) that the required certification be “completed … no more than 12 months before the time that the agreement is made,” CRA stated: This wording suggests that the Certification is to be completed before the time the flow-through share agreement is made (but not more than 12 months before that time), although it doesn’t expressly mandate that the Certification be completed before the flow-through share agreement is made (rather than after). ...

. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...

More specifically, paragraph (c) of the definition of AAII … deals with adjustments to the definition of "income" or "loss" as defined in subsection 129(4) and does not provide for any adjustment related to the Deemed ABI which is defined under paragraph 129(6)(b). ...

In responding, “yes,” CRA stated: [T]he fact that premiums and contributions paid by an employer are not made directly to a trust will also not, in and of itself, impair that trusts’ ability to qualify as an ELHT, as there is no requirement in section 144.1 … which explicitly requires that an employer make contributions directly to an ELHT (or to any extent whatsoever). ...

CRA responded: [A]s there is no income that is received (directly or indirectly, in any manner whatever) from the provision of services or property between ACo and BCo, there would not be any income that would be as described in subparagraph (a)(i) of the SCI definition …. ...

CRA then stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

The individual’s taxable capital gain arising from the transfer of the capital property to the CRT would not be included in variable B …. ...

In responding affirmatively, CRA stated: [S]ection 122.92 … does not require that an eligible dwelling be built prior to, or concurrently with, a secondary unit in order for qualifying expenditures to qualify for the MGHRTC. ...

Where a contribution is made in respect of new or future hires comprised of unidentified individuals, most of whom are not yet employees of the employer, this requirement would not be met and the contribution would not be deductible under subsection 144.1(6) …. ...