Search - 屯门 安南都护府

19 October 1999 External T.I. 9925055- GAINS & LOSSES ON OPTIONS-- summary under Options Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ... The trust in such an arrangement is a separate person for income tax purposes and therefore a stock call written outside an RRSP … would constitute a naked option. ...

7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose criteria of public policy and inevitability in IT-104R2 no longer applicable re fines and penalties/ provincial interest and penalties are non-deductible Regarding the deductibility of interest and penalties not coming within s. 18(1)(t), CCRA indicated (in its summary) its acceptance of 65302, and stated: [F]ines and penalties, as well as interest, not covered by the Act, will generally be deductible pursuant to paragraph 18(1)(a) to the extent that they were made or incurred for the purpose of gaining or producing income and are not otherwise capital expenditures described in paragraph 18(1)(b). The criteria of public policy and inevitability are therefore no longer applied in the context of the deductibility of expenses (penalties or other) referred to in paragraph 18(1)(a). … [I]ncome tax, penalties and related interest paid to a province are not expenses incurred for the purpose of earning income. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business-- summary under Paragraph 120.4(1.1)(a) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(a) spouse on achieving 20-hour threshold could receive large dividends as excluded amounts The spouse (the “Spouse”) of a professional (the “Individual”) owns non-voting preferred shares of his professional corporation (“XCo”) and works at least 20 hours per week as a part-time receptionist. ... CRA indicated that if Spouse works for XCo at least 20 hours per week throughout the portion of the year that the business operates, that would satisfy s. 120.4(1.1)(a), and the dividend income received by Spouse would be considered to be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business-- summary under Excluded Business Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Business an excluded amount can exceed arm’s length remuneration for the services rendered The spouse of a professional works over 20 hours per week as a part-time receptionist in the professional practice of his corporation (XCo). ... CRA indicated since she satisfies the 20 hours per week test in s. 120.4(1.1)(a), her dividend income would be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income. ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subsection 12(2.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(2.2) s.12(2.2) election can be made re s. 12(1)(x)(iv) inclusion for forgivable CEBA loan The Canada Emergency Business Account (“CEBA”) program provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

28 September 2023 CLHIA Roundtable Q. 1, 2023-0971701C6- Life insurance – contractual changes-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition a no-cost endorsement to a life insurance policy to add benefits could be a disposition Regarding whether an endorsement to provide a new benefit under an in-force exempt life insurance policy for no cost and without any underwriting requirement, to a defined set of policyholders, would constitute a disposition, CRA stated: [I]t is necessary to determine whether the changes that are made to the terms of the policy, including but not limited to endorsements providing additional benefits, are so fundamental as to go to the root of the policy. ... [This] is a mixed question of fact and law …. ...

7 May 2024 CALU Roundtable Q. 8, 2024-1007121C6- IPPs & Past Service Contributions-- summary under Subsection 8303(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 8303- Subsection 8303(6) a RRIF may not make a Reg. 8303(6) qualifying transfer to a RPP in connection with a past service event Where an individual pension plan (IPP) as defined in Reg. 8300(1) is established and a plan member is age 71 in the effective year of the plan, would CRA allow the qualifying transfer which is required as part of a past service contribution (typically satisfied by a transfer of the required asset value from a registered retirement savings plan) to be satisfied by the transfer of the required asset value from a registered retirement income fund (RRIF)? ... A transfer of property from a RRIF to a defined benefit provision of a registered pension plan (including an IPP) is not a qualifying transfer for purposes of [Reg.] 8303(6) …. ...

25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 PE to be determined under treaty of residence of employee rather than employer ACo is a British company that performed seismic surveys offshore Canada. ... Respecting the Norwegian and Netherlands treaties, CRA stated: Paragraph 1 of Article 21 of the Canada-Norway Treaty- Offshore Activities states that Article 21 applies notwithstanding any other provision of the treaty. … Subparagraph 5(a) of Article 21 states that…remuneration derived by an employee who is resident in Norway in respect of employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Canada may be taxed in Canada, but only if the employment exceeds 30 days in any 12-month period. Therefore, if the employment exceeds 30 days, remuneration paid by BCo to employees who are resident in Norway may be taxed in Canada. … Paragraph 3 of Article 23 [of the Netherlands Treaty] provides…that "an enterprise of one of the States" will be deemed to be carrying on business in Canada through a permanent establishment if the enterprise carries on Offshore Activities in Canada for more than 30 days in any 12 month period. ...