Search - 屯门 安南都护府

See… 2017-0709811I7 ….] ...

Joint Committee, "Avoidance of Tax Debts", 5 April 2022 Joint Committee Submission-- summary under Subsection 160.01(3) Summary Under Tax Topics- Income Tax Act- Section 160.01- Subsection 160.01(3) Clerical or secretarial services exclusion is too narrow (p. 10) The exclusion in s. 160.01(3) for clerical or secretarial services is too narrow – “it is entirely possible that a person may be more significantly involved in, for example, documenting the transaction, but without understanding the avoidance aspects of the plan as a whole (such as a corporate lawyer or valuator with no tax expertise). ...

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper-- summary under Subsection 18.21(2) Summary Under Tax Topics- Income Tax Act- Section 18.21- Subsection 18.21(2) Zero tolerance for errors (p. 39) Under s. 18.21(2), if an election is made that allocates an amount greater than the specified limits, the allocated group ratio amount will be deemed to be nil – a potentially punitive result for what might be a small error. ...

. … Regardless, the outcome in Nortel finally confirms that interest should no longer be deductible under paragraph 20(1)(c) unless otherwise provided for in the plan. ...

. … The specified factor of 0.35 operates as a form of rough justice, but does not distinguish between different rates of tax…. ...

. … ...

MNR, [fn 6: 70 DTC 1208 …]… [R]oland St-Onge QC compared the legal status of a GmbH under German law with the legal status of a corporation under Canadian law. ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under A Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(1)- Adjusted Taxable Income- A Double-deductions of non-capital losses Item A in the ATI formula is reduced by the non-capital loss and net capital loss generated for the current year – yet if these losses are applied in a future year, there is no consequential ATI adjustment for that subsequent year (except for the partial addback of the portion of a non-capital loss that reasonably relates to the taxpayer’s net interest and financing expense). ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under Acceptable Accounting Standards Summary Under Tax Topics- Income Tax Act- Section 18.21- Subsection 18.21(1)- Acceptable Accounting Standards Non-recognition of local European GAAP The group ratio rule in draft s. 18.21, which may enable taxpayers to access a higher fixed percentage than 30% where the group as a whole is bearing higher interest and financing expenses as a result of its external debt and as measured by the group GAAP financial statements, does not recognize any local European GAAP – so that the group ratio calculations could be unavailable for European-headed groups that do not consolidate using IFRS. ...

Joint Committee, "Reportable Transaction and Notifiable Transaction Proposals", 5 April 2022 Joint Committee Submission-- summary under Avoidance Transaction Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Avoidance Transaction Expansion of “avoidance transaction” (pp. 8-10) The change of the “avoidance transaction” test to refer to “one of the main purposes” of the transaction or series (rather than using a “primarily” test for a transaction) means that, for example, having a small safe income dividend (representing an acceptable tax benefit) as part of a series would render all transactions in the series avoidance transactions – so that the presence of only one hallmark would engage a reporting requirement. ...