Search - 屯门 安南都护府
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Conference summary
5 October 2012 Roundtable, 2012-0453181C6 F - Person affiliated with RESP and RDSP -- summary under Paragraph 251.1(1)(g)
. … Finally, any person who would be affiliated with a majority-interest beneficiary in a particular RDSP Trust in the absence of paragraph 251.1(1)(g), should generally be affiliated with such trust. ...
Conference summary
11 October 2013 APFF Roundtable, 2013-0495651C6 F - Revenu fractionné -- summary under Paragraph (c)
11 October 2013 APFF Roundtable, 2013-0495651C6 F- Revenu fractionné-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) streaming of non-split income to child discretionary beneficiary and split income to mother A discretionary family trust with Father, Mother and a 15-year old Child as beneficiaries, holds a building with two premises – the first leased to an arm's length tenant; and the second, to a professional corporation of Father and Mother. ...
Conference summary
16 June 2014 STEP Roundtable, 2014-0523021C6 - Multiple assessments - STEP Q19 -- summary under Subsection 220(3.1)
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Conference summary
9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 9, 2015-0596611C6 F - Transfer 70(6) -- summary under Subsection 70(6)
. … If an executor, in performing the estate administration, is under an obligation to dispose of property or he exercises his power to dispose of the property… subsection 70(6) is not complied with since the property has not vested indefeasibly in the trust. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Paragraph 87(2)(z.1)
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Capital Dividend Account
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
24 November 2015 CTF Roundtable Q. 1, 2015-0610691C6 - T2 Late-Filing: Impact on Div. Refund and RDTOH -- summary under Subsection 129(1)
. … As well, the CRA will consider that a dividend recipient’s Part IV tax liability with respect to a dividend received from a connected dividend payer will be determined according to the dividend refund actually received by the dividend payer. ...
Conference summary
17 November 2015 Roundtable, 2015-0614251C6 - 2015 TEI Meeting Q7 Donations to qualifying US charity -- summary under Article 21
These sourcing rules are generally set out in Folio S5-F2-C1 …. For the purposes of paragraph 7 of Article XXI of the Treaty, the CRA’s view is that “income” includes the taxable portion of a capital gain. ...
Conference summary
21 January 2016 Roundtable, 2016-0625131C6 F - Farming losses -- summary under Subsection 31(1)
. …. [T]he comments of the Supreme Court of Canada on the considerations mentioned in previous paragraphs could still be relevant. ...
Conference summary
26 May 2016 IFA Roundtable Q. 6, 2016-0642081C6 - German Organschafts -- summary under Clause 95(2)(a)(ii)(B)
., 2001-0093903) that a profit transfer payment made by Subco to Parentco could be re-characterized as income from an active business of Parentco under s. 95(2)(a) to the extent that Subco had earnings from an active business before taking into account the profit transfer payment – so that this previous position will only apply to profit transfer payments made before 2017. ...