Search - 屯门 安南都护府
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Conference summary
10 June 2011 Roundtable, 2011-0404621C6 F - Rectification order in Québec -- summary under Rectification & Rescission
10 June 2011 Roundtable, 2011-0404621C6 F- Rectification order in Québec-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission CRA awaiting resolution of AES and Riopel cases CRA noted that as the ARQ had sought leave to appeal the AES decision to the Supreme Court and the period for seeking leave in Riopel had not yet expired, it would prefer to refrain from commenting on those decisions effect on CRA’s views on rectification. ...
Technical Interpretation - External summary
25 March 2009 External T.I. 2008-0300401E5 F - Fiducie en faveur de soi-même - prêt sans intérêt -- summary under Payment & Receipt
25 March 2009 External T.I. 2008-0300401E5 F- Fiducie en faveur de soi-même- prêt sans intérêt-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt individual pays trust taxes when he receives trust distributions net of such taxes CRA indicated that an individual would be considered to be personally paying taxes of a trust that had made a s. 104(13.1) where he received distributions from the trust net of such taxes. ...
Administrative Letter summary
6 July 1994 Administrative Letter 9323826 F - Bonds Issued in Lieu of Interest -- summary under Payment & Receipt
6 July 1994 Administrative Letter 9323826 F- Bonds Issued in Lieu of Interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of bonds re accrued interest did not constitute payment thereof Bonds issued to a Canadian bank in settlement of arrears interest on a non-performing loan of a Brazilian debtor would not be considered to constitute payment by the debtor and receipt by the bank of interest on the underlying loans, in light of the comments in Cross v. ...
Conference summary
5 January 1996 CTF Roundtable Q. 31, 9523976 - GROSS-UP PAYMENTS -- summary under Payment & Receipt
5 January 1996 CTF Roundtable Q. 31, 9523976- GROSS-UP PAYMENTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where the gross-up is paid or credited to the government of a foreign country on the Canadian lender's behalf since the Canadian lender would have constructively received the gross-up". ...
Technical Interpretation - External summary
29 April 2003 External T.I. 2002-0177065 F - CONFISCATION DE LA SOLDE -- summary under Payment & Receipt
29 April 2003 External T.I. 2002-0177065 F- CONFISCATION DE LA SOLDE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received CCRA indicated that salary that was forfeited by RCMP officer for misconduct nonetheless was to be treated as includible in the officer’s income as salary which was to be treated as having been received by the individual before its forfeiture as a fine. ...
Technical Interpretation - Internal summary
25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE -- summary under Payment & Receipt
25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital CCRA reviewed the line of cases culminating in Teleglobe, and concluded that the amount paid by the issuer on the conversion of its convertible debentures should be treated as the stated capital of the shares issued, which equaled the face amount of the converted debentures. ...
Ruling summary
2021 Ruling 2021-0911211R3 - Foreign Takeover -- summary under Payment & Receipt
2021 Ruling 2021-0911211R3- Foreign Takeover-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt borrowing and payment of funds pursuant to an internal payment direction agreement CRA ruled on transactions which included the borrowing of money by a newly-formed non-resident corporation (Merger Sub1) from a Canadian affiliate (Opco) and its advance of such funds to a transfer agent for shareholders of a non-resident target (Target), pursuant to directions in an internal funding agreement. ...
News of Note post
8 November 2018- 12:00am Atlas Tube – Federal Court finds that CRA could compel disclosure of an EY tax due diligence report discussing uncertain tax filing positions of a target Email this Content The U.S. parent (JMC) of the Canadian taxpayer (Atlas) acquired another Canadian company (LSI), following which some of the pieces of LSI ended up in Atlas’ hands in a post-closing reorganization. ... In rejecting this argument, Southcott J stated: BP is to be read as precluding general and unrestricted access to TAWPs on a prospective basis, outside the context of an audit of particular issues. … … Unlike in BP, the Minister’s request for access to the Report in the present case is made in the context of an active audit of particular issues. ... Atlas Tube Canada ULC, 2018 FC 1086 under s. 231.1(1) and s. 232(1) – solicitor-client privilege. ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide – Chapter 4 – Inventories, purchased inputs, deferrals, receivables and payables
For example, if you have 350 taps producing, you enter 3.5 (350 ÷ 100 = 3.5). ... You receive ⅔ of the crop and pay ⅔ of the allowable expenses. Your landlord receives the remaining ⅓ of the crop and pays ⅓ of the allowable expenses. ... Example If you had 9,500 pre-harvested trees at the end of your fiscal period, enter 9.5 acres (9,500 ÷ 1,000 = 9.5). ...
Decision summary
Anderson v Benson Trithardt Noren LLP, 2016 SKCA 120, aff'd 2017 SCC CanLii 8568 -- summary under Rectification & Rescission
Anderson v Benson Trithardt Noren LLP, 2016 SKCA 120, aff'd 2017 SCC CanLii 8568-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission drop-down documents could not be declared retroactive to the previously-agreed effective date, as this would undercut the Tax Court The taxpayer’s accountants met with him on October 6, 2011, when it was agreed that he would transfer personally-owned land and equipment on s. 85 rollover basis to his corporation in order to facilitate paying off a loan owing by him to the corporation. ... In dismissing the appeal, Lane J. stated (at paras 29, 34): … The Chambers judge was correct to limit the application of the rectification remedy as he did. He saw the application for a declaration for what it was – an attempt to obtain equitable relief not available from the Tax Court, which is a superior court of record but not a court of inherent jurisdiction, and to thereby attempt to determine the outcome of an assessment appeal by essentially binding the hands of that Court. … The Chambers judge properly limited his decision to the issue between the appellants themselves. ...