Search - 哈尔滨到北京 公里数

. … [T]o conclude that the portion of the salary paid to a chef hired by a corporation to prepare meals for the staff during the stages from the final script stage to the end of the post-production stage would be to ignore the adverb "directly" used by the legislator in paragraphs (a) and (b) of the definition of LE. … Similarly … the accounting fees that a corporation must incur to meet CFVP requirements and the legal fees that a corporation must pay to an actor's agent to negotiate the actor's contract are certainly expenses that are necessary and parallel to the production of a CFVP, but we doubt that those expenses are directly attributable (i.e., in immediate relation) to the production of a CFVP and relate to the final script stage to the end of the post-production stage. ...

In computing Part XII.6 tax of the PBC for February to June 2020, it is deemed to have incurred $3M of CEE before the end of those months, so that the tax would be computing (applying the prescribed rate of 2%) in accordance with the formula: ($5M- $3M) X (0.02/12 + 0/10) = $3, 333.33 so that the tax for each month during that period is $3,333. ...

On the sale, it realized a capital gain of $50,000 and a terminal loss of $60,000 – except that, pursuant to s. 13(21.1), the capital gain became nil and the terminal loss became $10,000, so that pursuant to s. 13(21.1), the deemed proceeds of disposition of the building were $250,000. The Directorate stated: [T]he expression “that would otherwise be the transferor’s proceeds of disposition of the transferred property” used in paragraph 13(21.2)(b) means the proceeds of disposition of the building determined having regard to subsection 13(21.1) … [i.e.] $250,000 … [so that] the vendor would be deemed to own a property with a capital cost of $10,000. ...

. … [T]he term "group … insurance plan”… includes, in particular, accidental death and dismemberment insurance plans. Therefore, if the Insurance Coverage is a group insurance plan, we are of the view that the total amounts paid by the Employer in respect of an employee during a year of Insurance Coverage is to be included in computing the employee's income from an office or employment under paragraph 6(1)(e.1). … [T]hat the Insurance Coverage primarily benefits the Employer … is not relevant for the purposes of paragraph 6(1)(e.1). ...

. … It is … not required that the services be rendered to the payer, either the directors of the corporation (the employer) or the administrator of the settlement fund. ...

After quoting from Nassau Walnut to the effect that a late designation was acceptable where the situation “ does not raise the spectre of retroactive tax planning,” the Directorate stated: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... We refer you to … Klein [which] stated: …[T]he partnership itself does not have the capacity to be indebted. The debt of the partnership is owed by the partners …. ...

23 June 2010 Internal T.I. 2010-0368161I7 F- 84.1-- summary under Paragraph 84.1(2)(b) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(b) s. 84.1(2)(b) inapplicable to individual’s transfer of ½ of Opco to Holdco (owned by 3 unrelated individuals) for note and non-voting pref Three individuals (A, B, and C) each held 1/3 of the shares of Holdco, and Holdco and another individual, D, each held ½ of the shares of Opco. ... [Thereafter] … the Purchaser … is controlled by a group of 4 persons consisting of A, B, C and D (the Final Group). ... Consequently, the deeming provision in paragraph 84.1(2)(b) could not apply …. ...

14 October 2011 Internal T.I. 2011-0410781I7 F- Repas fournis gratuitement-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit from free meals delivered on-site Respecting a proposal that employees would receive a catered meal service during their shifts, CRA stated: [T]o the extent … the provision of free meals … primarily benefits the employees and not primarily their employer, … the value of that benefit should be included in computing the income of those employees. ...

., $1,800 = $1,000 + $800). Neal Armstrong. Summary of 20 January 2021 Internal T.I. 2019-0832211I7 under s. 126(1). ...