Search - 广东省2002政府工作报告 一小发展 金句

28 May 2002 External T.I. 2002-0131535- incorporation-professional Unedited CRA Tags 125 256(2.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-013153 Allan Nelson, C.M.A. (613) 443-7253 May 28, 2002 Dear XXXXXXXXXX: Re: Technical Opinion Request We are writing in reply to your letter to us dated March 19, 2002, concerning the taxation of professional corporations and their management services entity. ... ManagementCo was incorporated a number of years ago and solely provides administrative support services to the Law Partnership, and bills the Law Partnership on a cost + 15% basis. ...

16 July 2002 External T.I. 2002-0142475- INTEREST DEDUCTIBILITY INCOME TRUST Unedited CRA Tags 20(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Moore July 16, 2002 Dear XXXXXXXXXX: Re: Interest Deductibility This is in reply to your letter of May 21, 2002, regarding interest deductibility with respect to money borrowed to invest in an income trust. ... Therefore, assuming that the total interest expense incurred for the second year is $400, it is our view that interest of $36 ($900/$10,000 X $400 = $36) would not be deductible for the second year pursuant to paragraph 20(1)(c) of the Act since $900 of the original investment of $10,000 is no longer being used for income earning purposes. ...

10 July 2002 External T.I. 2002-0143035- SUPERFICIAL LOSS Unedited CRA Tags 40(2)(g) 54 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 10, 2002 Dear XXXXXXXXXX: Re: Superficial Loss We are writing in response to your letter of May 17, 2002, wherein you requested our comments regarding the application of the definition of "superficial loss" in section 54 of the Income Tax Act (the "Act") in a number of specific situations related to the purchase and sale of securities. ... With respect to a number of questions you submitted, please note that where fewer securities are acquired during the relevant period than were of disposed during the period or when fewer securities are left at the end of the period than were acquired during the period, the Canada Customs and Revenue Agency ("CCRA") administratively accepts that the amount of the superficial loss be determined by using the following algebraic formula: S/L = (Least of S, P and B)/S x L where S/L is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 60 day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...

7 October 2002 External T.I. 2002-0145205- ARMS LENGTH BOARD AND CHARITABLE DESIGNATION Unedited CRA Tags 149.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-014520 Alison Campbell October 7, 2002 Dear XXXXXXXXXX: Re: Board of Directors of a Charity We are writing in reply to your letter dated June 3, 2002, wherein you requested our comments on the requirements for charities to have board of director members that deal at arm's length. ... In addition to Interpretation Bulletin IT-419R, we have enclosed for your reference, CCRA Guide number RC 4108(E) "Registered Charities and the Income Tax Act ". ...

22 January 2002 External T.I. 2001-0096445- SPECIFIED INVESTMENT BUSINESS Unedited CRA Tags 123(7) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Grisé January 22, 2002 Dear XXXXXXXXXX: Re: Specified Investment Business This is in reply to your letter of August 6, 2001, requesting our interpretation of the expression "throughout the year" in the definition of "specified investment business" in subsection 125(7) of the Income Tax Act (the Act). Your enquiry stemmed from your review of an interpretation we issued on March 6, 2001 (document # 2000-0049105) where we concluded that a corporation carried on a "specified investment business" since it did not employ more than 5 full-time employees for the portion of the year after two rental properties were surrendered at the same time due to foreclosure. ...

28 January 2002 External T.I. 2001-0115515- SALE OF A FARMING BUSINESS Unedited CRA Tags 28(1)(d) 40(1) 12(1)(b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Reasons: (1) Subsection 13(1), paragraph 28(1)(d) and paragraph 40(1)(a). (2) Paragraph 12(1)(b) & 28(1)(d) XXXXXXXXXX 2001-011551 Randy Hewlett, B.Comm. January 28, 2002 Dear XXXXXXXXXX: Re: The Sale of a Farming Business We are writing in response to your letter dated December 14, 2001, wherein you requested our opinion on the above-noted matter. ...

18 February 2002 External T.I. 2001-0112055- SUPERFICIAL LOSS ON SHARES Unedited CRA Tags 40(2)(g) 251.1 54 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Principal Issues: Where an individual disposes of shares to a personal Holdco & Holdco immediately thereafter disposes of same shares to individual's self-directed RRSP will 1) 40(2)(g)(i) apply? ... Holloway 613-957-2104 February 18, 2002 Dear XXXXXXXXXX: Re: Technical Interpretation Request- Loss on transfer of Shares to RRSP This is in reply to your letter of November 15, 2001 requesting a written opinion on specific proposed transactions in respect of your client's self-directed RRSP. ...

27 February 2002 External T.I. 2002-0121305- DAMAGES-RETIRING ALLOWANCE Unedited CRA Tags 248(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Position: question of fact Reasons: some amounts may be considered retiring allowance and therefore taxable XXXXXXXXXX 2002-012130 Shaun Harkin, CMA February 27, 2002 Dear XXXXXXXXXX: Re: Technical Interpretation Request: Minutes of Settlement This is in reply to your letter of November 13, 2001 wherein you requested our views on whether a settlement payment received by a taxpayer from a former employer is subject to income taxation. ... The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope". ...

25 April 2002 External T.I. 2001-010587A- SPECIFIED INVESTMENT BUSINESS-MORE THAN 5 FTE Unedited CRA Tags 125(7) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2001-010587 Patrick Massicotte, CA April 25, 2002 Dear XXXXXXXXXX: Re: Specified Investment Business We are writing in response to your letter of October 15, 2001, wherein you requested our comments regarding the interpretation of the provisions of subsection 125(7) of the Income Tax Act (the "Act"). ... We would also note that the allocation of an employee and the totalling up of bits and pieces so as to arrive at more than 5 full-time employees is generally not considered by the courts as being consistent with the intention of the provision (see Federal Court of Appeal and Tax Court of Canada decisions in Lerric Investments Corp. and Federal Court-Trial Division decision in Hughes & Co. ...

20 June 2002 External T.I. 1999-0013055- 75(2)(b) where settlor is sole trustee Unedited CRA Tags 75(2)(b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 1999-001305 Annemarie Humenuk Attention: XXXXXXXXXX June 20, 2002 Dear XXXXXXXXXX: Re: Application of Paragraph 75(2)(b) to the Sole Trustee of a Trust This is in reply to your letter of October 7, 1999, concerning the application of paragraph 75(2)(b) where the sole trustee of a trust has contributed property to the trust. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...