Search - 屯门 安南都护府
Results 371 - 380 of 652 for 屯门 安南都护府
Article Summary
Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661. -- summary under Canadian Resource Property
Canadian Pipelines & Petroleum Limiter et al. [fn 11: (2959), 21 DLR (2d) 497 (S.C.C.) at 169-70, although we note that in the particular case, the Court found that the option was rendered void and of no effect because of a regulatory prohibition. ...
Article Summary
Doron Barkai, Alexander Demner, "Dealing with New Subsection 55(2): Issues and Strategies", 2016 Conference Report (Canadian Tax Foundation), 6:1–56 -- summary under Subsection 248(10)
. … [M]any tax practitioners are concerned that any dividend that would entitle the corporation to recover the part IV tax could be included in the series of transactions because the jurisprudence has generally ascribed a very broad interpretation to the phrase "series of transactions. ...
Article Summary
Pooja Samtani, "Requirements on the Rise: Defending Against Demands for Taxpayer Information", Tax Management International Journal, 2013, p. 357 -- summary under Subsection 231.2(1)
Canada Customs & Revenue Agency, 2004 FC 573 at ¶33, aff'd 2005 FCA 68.] ...
Article Summary
Austin del Rio, "Part VI.1 Tax on Dividend Paid Through Family Trust", Tax for the Owner-Manager, Vol. 19, No. 3, July 2019, p. 9 -- summary under Subsection 191.1(2)
X. … Mr. X owns voting preferred shares, allowing him to control Opco. ... X …. Thus, Holdco should have a substantial interest in Opco. Whether trust has a substantial interest (p. 10) [T]he CRA has confirmed that a trust will be related to a person if that person is related to all of the trustees of the trust (2009-0311891l70…and 2002-0117885 …). ... [A]ny corporate beneficiaries of the trust will be controlled by another beneficiary and should also be related (subparagraphs 251(2)(b)(i) and (iii)). … [A]ny trusts that are beneficiaries of the trust will likely be related when the trustees of such trusts are related to the other beneficiaries of the trust. … [U]nrelated trusts may still be beneficially interested in the trust, even before their creation….due to the broad meaning of “beneficially interested,” … [in s.] 248(25)…. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 248(8)
. … A beneficiary who executes a valid disclaimer in respect of property to be received under a will is considered never to have received the property. [F.n.184 … S6-F2-C1, paragraph 1.10]. When a person executing a disclaimer receives consideration, a question can arise whether the disclaimer is valid... In the common-law provinces and territories, a release or surrender refers to an extinguishment or discharge of a right to property. … If property is disclaimed, released, or surrendered, do the executors have the power under the terms of a will to transfer the property to a spousal trust? ...
Article Summary
Manon Thivierge, "Income Tax Due-Diligence Considerations in Mergers and Acquisitions", 2015 Conference Report (Canadian Tax Foundation), 18:1-29 -- summary under Subsection 89(11)
As a result, an M & A transaction may cause multiple year-ends for a target that is a CCPC. ... The closing of the sale of the target's shares takes place on December 1, 2015. … [T]he target will have a fiscal year-end on August 31, 2015. ... Consequently, an election under subsection 89(11) will not have any impact on the target's ability to claim the manufacturing and processing profits deduction under paragraph 125.1(1)(a) or the enhanced ITC for SR & ED. ...
Article Summary
Andrew Linton, Jillian Adams, "CRA Denies Voluntary GST/HST Registration for Financial Institutions", Canadian Tax Focus, Vol. 9, No. 4, November 2019, p. 7 -- summary under Subsection 240(3)
. … [A] listed financial institution that is registered for GST/HST can file returns and self-assess tax on imported taxable supplies on an annual basis. … [O]n the other hand, a registered entity may also have to file an annual information return if it is a “reporting institution” (ETA subsection 273.2(2)). … [W]hile an unregistered entity may have to remit tax on a monthly basis, a registered entity may have to pay tax only once or twice a year…. ... However, the CRA is increasingly refusing such applications; its reason is that the existence of a Canadian branch does not make the financial institution a Canadian resident for GST/HST purposes. … [A]ccording to ETA subsection 132(2), a non-resident person with a permanent establishment in Canada is considered to be resident in Canada in respect of the person's activities carried on through that establishment; thus, such a company should meet the definition of a listed financial institution resident in Canada (ETA paragraph 240(3) (c)) and should be allowed to register for GST/HST on a voluntary basis. ...
Article Summary
Henry Shew, "Foreign Affiliate Dumping and Estates with Non-Resident Beneficiaries", Canadian Tax Focus, Vol. 10, No. 1, February 2020, p.9 -- summary under Subsection 212.3(26)
. … [T]he normal tax arising from the deemed disposition on death is supplemented by a deemed dividend from Opco to NR son of $100,000 (the FMV of property transferred by Opco to US FA). This occurs at the dividend time (defined in subsection 212.3(4)), which is one year after Opco capitalized US FA. … Effect of s. 212.3(26) (p. 9) NR son will be deemed to own 100 percent of the voting shares of Opco. Thus NR son is deemed to control Opco when Dad passes away. … Potential outs (pp. 9-10) The elective PUC reduction relief contained in section 212.3 is helpful only to the extent that Dad has capitalized Opco with more than nominal capital. … If Opco’s investment in US FA is a pertinent loan or indebtedness (PLOI), as defined in subsection 212.3(11), then the FAD amendments will not apply…. ...
Article Summary
Richard Tremblay, Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One", Tax Management International Journal, 2018, p. 125 -- summary under Article 5
Formula One contravenes the requirement for separate-entity determination of a PE (p. 126) Philip Morris … held that an Italian corporation can be considered the permanent establishment of multiple non-resident members of the same corporate group. … [In response] paragraph 41.1 of The 20I0 Model Treaty Commentary on Article 5(7) (now paragraph 117 of the 2017 Model Treaty Commentary) states that: The determination of the existence of a permanent establishment under the rules of paragraph 1 or 5 of the Article must, however, be done separately for each company of the group. ... Control exercised analogous to that of franchisor (pp. 127-128) [T]he high degree of control provided for in its contract with Jaypee should be acceptable given FOWC's reasonable concern for preserving a quality product …. ... Inappropriate reliance on Fowler (p. 128) Fowler has never been followed in Canada …. ...