Search - 屯门 安南都护府
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Conference summary
15 November 2016 Roundtable, 2016-0672321C6 - Guidance on determination of safe income -- summary under Paragraph 55(2.1)(c)
. … The onus is on the taxpayer to provide support for the calculation of safe income that can reasonably be viewed as contributing to the capital gain on a share. The CRA expects the supporting documentation to be organized as an accumulation of year-by-year computations. … …[W]here…the taxpayer offers an alternative proxy such as the accounting retained earnings or adjusted retained earnings balance…the CRA auditor might conclude that retained earnings is a fair proxy for safe income on hand but only after a very stringent validation process. ...
Conference summary
27 November 2018 CTF Roundtable Q. 5, 2018-0780041C6 - GAAR on PUC reduction -- summary under Paragraph 88(1)(b)
Subco used $2,000 borrowed from a third party to acquire assets with a cost amount of $3,000 – which subsequently lost all their value. ... Parentco would essentially have taken two deductions for the same loss of $1000 – first the $1000 loss on the Subco shares under 50(1), and an additional loss of $1000 on the assets of Subco. ...
Conference summary
7 October 2021 APFF Roundtable Q. 17, 2021-0901071C6 - Application of section 120.4 -- summary under Subparagraph (e)(i)
. … Consequently, the dividend received by Ms. Y could qualify as an excluded amount pursuant to subparagraph (e)(i) …. ...
Conference summary
6 December 2011 TEI Roundtable Q. 5, 2011-0427001C6 - 2011 TEI Q#5 - Distributions from Foreign Corp. -- summary under Subsection 90(3)
. … [A]s a practical matter…[w]here the distribution is a dividend or a return of legal capital under the foreign corporate law, that characterization will generally not be challenged by the CRA. ...
Conference summary
7 October 2011 Roundtable, 2011-0411951C6 F - Retenues à la source - options d'achat d'actions -- summary under Paragraph 6204(1)(b)
7 October 2011 Roundtable, 2011-0411951C6 F- Retenues à la source- options d'achat d'actions-- summary under Paragraph 6204(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(b) loss of prescribed share status where employer granted redemption right to cover s. 153(1.01) withholding obligations In order to effect s. 153(1.01) withholding, certain employers have some shares redeemed immediately following the exercise of employee stock options in order to raise the requisite source deduction amount – and to accomplish this, the stock option agreements are amended to give the employer the right to redeem the shares in part. ...
Conference summary
9 October 2009 APFF Roundtable Q. 5, 2009-0327001C6 F - Succession canadienne - dividende en capital -- summary under Paragraph 212(1)(c)
. … Where applicable, the distribution would be subject to a withholding tax pursuant to subsection 212(11) and paragraph 212(1)(c)…. ...
Conference summary
9 October 2009 APFF Roundtable Q. 5, 2009-0327001C6 F - Succession canadienne - dividende en capital -- summary under Subsection 212(11)
. … Where applicable, the distribution would be subject to a withholding tax pursuant to subsection 212(11) and paragraph 212(1)(c)…. ...
Conference summary
8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1) -- summary under Subsection 110(2.1)
In the situation described … those two conditions are not satisfied. ...
Conference summary
7 October 2011 Roundtable, 2011-0413081C6 F - 227(4) et (4.1) - vente d'un bien à un tiers -- summary under Subsection 227(4)
That position is supported … in First Vancouver Finance. ...
Conference summary
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3 -- summary under Paragraph 212.3(10)(a)
. … See summary under s. 212.3(2). ...