Search - 哈尔滨到北京 公里数

. … CRA went on to note: The reduction in ACB for foreign taxes paid on behalf of a partner may occur prior to the addition to the ACB for the allocation of foreign income to the partner which is made on the first day of the following fiscal period. ...

In that case, the municipality is merely acting as a conduit for the other person, and it is our view that amounts received by the municipality on behalf of the other person do not qualify as gifts to a municipality …. ...

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

. … [I]t is our view that the First Parking Space is a component of the housing unit (i.e., the Condo). ...

CCRA stated: [T]he Agency's position … is that a corporation that redeems shares held by one of its shareholders may pay its entire capital dividend account to that shareholder, provided that subsection 83(2.1) does not apply. ...

. … Expenses paid to a “private health services plan” as a premium, contribution or other consideration in respect of, among others, the individual or the individual's spouse generally qualify as medical expenses under paragraph 118.2(2)(q) except to the extent that the payment was deducted by the individual as a business expense under subsection 20.01(1). ...

. … [F]or an individual disability insurance policy to be a component of a group insurance plan, it must be determined whether the level of benefits and the ratio of contributions to the plan shared by the employer and the employee are similar to those of the other employees covered by the same plan. ...

After noting that there would be no taxable benefit under s. 6(1)(a) from the employer's payment of the premiums if this arrangement qualified as a group plan described in s. 6(1)(a)(i), CRA went on to note that its general presumption “that an employee shareholder receives benefits or allowances in their capacity as a shareholder if they can significantly influence the policies of the corporation” can be rebutted if “all employees of the corporation are entitled to the benefit” or if all employees are shareholders or related to a shareholder and the benefit “is comparable (in nature and amount) to the benefits … generally offered by corporations of the same size to non-shareholder employees whose services and responsibilities are similar.” ...

Consequently, in the example … a trust created for a minor child under the will would be considered a “testamentary trust” under the definition in subsection 108(1), assuming that paragraphs (a), (b) and (c) of that definition do not apply. ...