Search - 哈尔滨到北京 公里数

CALU CRA Roundtable – May 2014 Question 1- LIA Policies Background Changes resulting from Budget 2013 have eliminated many of the tax benefits associated with leveraged insured annuities (LIA). ...

Evidence of payable to Minor from Trust Position: 1.Promissory note to Guardian Reasons: 1.Issue dealt with previously see 2010 Step q.2 Ontario CTF Conference – October 30, 2012 Question-20 This question deals with CRA's view on a demand loan to a minor beneficiary issued as "payment" for income designated from a trust. ...

10 June 2013 STEP Roundtable, 2013-0480261C6- 2013 STEP Roundtable Question 1 CRA Tags 120.4 Principal Issues: Kiddie Tax Position: Various questions Reasons: General comments provided 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 1. ...

Position: Yes Reasons: In cases where services are subcontracted to a Canadian resident entity for an arm's length fee, the correct amount of income will be taxable in Canada, without creating an undue administrative burden on US resident. 2011 CTF – November 2011 Question 25 Canada-US Tax Convention- Permanent establishment Part A A US company ("USCo") enters into a contract to provide consulting services to Canco, an arm's length customer resident in Canada. ...

Based on his interpretation of Duha (particularly in light of paragraph 85 of that decision), Justice Bédard concluded that the Particular Person could not have had de jure control of Bagtech, despite his view that "the clauses of the USA that are genuinely in the nature of a unanimous shareholders' agreement (that is, that restrict the power of the directors) […] do not operate to strip the hypothetical shareholder of de jure control". ...

/ What are CRA views in respect of a company which has received management fees from a related company when the related company is denied the deduction of such fees following an audit? ...

Since the capital gain was created to allow the appellants to receive the Class A shares with a maximum adjusted cost base and paid-up capital, I find that the transactions at issue allowed the appellants to use the value accumulated before 1971 to indirectly distribute part of Oka’s surpluses tax-free. (…) The result of all three transactions described above is that the tax-exempt margin made it possible for part of Oka’s surplus to be distributed to the appellants tax-free in a manner contrary to the object, spirit or purpose of section 84.1 of the Act. ...

.), at para. 458 7 This description was used in a UK decision, Laerstate BV v HM Revenue & Customs [UKFTT 09 (TC). ...

More recently the CRA has expressed the view in Technical Interpretation 2014-0521301E5 (dated June 25, 2014) that: …. a cost-plus plan under which the administrator agrees to reimburse the sole employee-shareholder, his or her spouse, and members of his or her household for actual medical and hospital expenses and receives, as consideration, an amount equal to the amount reimbursed plus an administrative fee, does not qualify as a PHSP since it does not contain the necessary elements of insurance. ...

Position: See response. 2011 TEI-CRA Liaison Meeting December 6, 2011 Question 7- Risk-Based Audit Approach HM Revenue & Customs in the United Kingdom has published substantial guidance about its risk-based audit approach for large businesses. ...