Search - 广东省2005政府工作报告 一小发展 金句

In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... Regarding the first question, a similar question was asked at the 2005 APFF Roundtable. ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...

Email this Content 27 October 2020 CTF Roundtable Q.1 – ACB increase in s. 55(3)(a)/88(1) reorg Preliminary Response Official Response Q.2 – Consolidation of safe income in a corporate group Preliminary Response Official Response Q.3 – Safe Income on Reorganization Preliminary Response Official Response Q.4 – Sale of taxable Canadian property by a partnership Preliminary Response Official Response Q.5 – Art. ... Treaty where further French layer Preliminary Response Official Response Q.6 – MLI and PPT Preliminary Response Official Response Q.7 – Use of cottage by children of settlor of AET/JST/CLPT Preliminary Response Official Response Q.8 – SDA rules and formula-based appreciation plans Preliminary Response Official Response Q.9 – UK LLPs as corporations Preliminary Response Official Response Q.10- Refreezes and s. 74.4(2) attribution quantum Preliminary Response Official Response Q.11 – Refinancing prescribed rate loans and attribution Preliminary Response Official Response Q.12 – Impact of COVID-19 on Previous APAs/Current MAPs Preliminary Response Official Response Q.13 – Reimbursement of Equipment Preliminary Response Official Response Q.14 – Section 86 Reorganization of Capital Preliminary Response Official Response This provides the text of the written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable webinar hosted on 27 October 2020 by the Canada Tax Foundation. ... Last, but not least, the CRA supports that policy through the administration of the GAAR which was clarified back in 2005 as retroactively applying in treaty situations. ...

Royal Bank (2005 TCC 802) suggests that paragraph (q) would not apply since distribution services should not be considered to be an “administrative service”. ... Summary of Facts A supplier (“ Québec Co. ”) manufactures widgets for its customer (“ Ontario Co. ”). ... R., 2005 FCA 333; Gastown Actors Studio Ltd. v. R., [2000] G.S.T.C. 108 (Fed. ...

Those shares would not qualify as shares of a “ specified class ”, in particular because of paragraph 256(1.1)(b), which requires that the shares not carry voting rights. ... Canada, [13] a decision rendered by the Supreme Court of Canada in 2005 [14]. ... C-44 4 Id., par. 67. 5 Id. at par. 68. 6 Id. at para. 69. 7 Id. 8 97 D.T.C. 111 (T.C.C.) (“ McNichol ”) 9 2014 TCC 75 10 2022 TCC 13 12 2013 FCA 110 13 2005 SCC 54 14 Foix, supra, note 6, par. 77 15 CANADA REVENUE AGENCY, Technical Interpretation 2002-0156695, October 11, 2002. 16 97 D.T.C. 302 (T.C.C.) 17 CANADA REVENUE AGENCY, Technical Interpretation 2007-0224151E5, August 13, 2007. 18 CANADA REVENUE AGENCY, (online: https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/foreign-reporting/questions-answers-about-form-t1134.html). ...

Selected Listed Financial Institution – Rebate of PVAT Summary of Question CRA Response Q.29. ... Regent Trust Company Limited, (2005), J.L.Rev. 198 (CA) at para. 20). ... Recognition of nominee/prête-nom Summary of Question TVQ16-30/R1 « Contrat de prête-nom » states: “All persons may hold property of others under a nominee agreement. ...

Official Response 15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Q.2- Withholding if swap mismatches A Canadian resident taxpayer (Canco) enters into a Swap Agreement (Swap Agreement) with a non-arm’s length non-resident company (NRco). ... The last update was in 2005 and a lot has occurred internationally since then, including the BEPS project. ... This is where the wage subsidy – we’ll say $10 in this case – would be taken into account. ...

The CRA requires that form T2075 be filed twice – this is noted at the top of the form. ... A forgiven amount at any time is determined by the formula A – B, under that definition in s. 80(1). ... Official Response 15 June 2022 Roundtable, 2022-0924791C6- STEP 2022 – Q18- McNeeley et al v. ...

Designations under subsection 104(13.1) and (13.2) We have noted in the past (for example in the 2005 document above) that a designation under subsection 104(13.1) or (13.2) may be utilized to have income that is otherwise paid or payable to beneficiaries taxed in the estate. ... This is claimed by filing form T3A — Request for Loss Carryback by a Trust. ... Because of these strict requirements, practitioners have for years been concerned — and experienced the results of such concerns — that many estates may not be eligible for such planning because of the tight timelines and requirements for an actual disposition. ...

The preamble to s. 104(4) states that the deemed disposition dates apply to each property of the trust – that is, the dates are not tied to specific properties. S. 104 might not apply in the circumstance, because s. 108(1) – “trust” – (g) generally provides that the s. 104(4) will not apply to a trust in which all interests have vested indefeasibly. ... The result is the same as it was in the first scenario for the person who is just the shareholder in that s. 15(1.4)(c) won’t apply, for the same reason – the amount of the wages are already included in the shareholder’s income – in this case, the shareholder-employee’s employment income. ...

c) Would the registrant’s disclosure application be considered as Category 1 – wash transactions (100% penalty and interest relief) or Category 2-general (100% penalty and 50% interest relief) if returns were not filed for 7 years, but all the uncharged HST involved wash transactions? ... The West Windsor Urgent Care decision (2005 TCC 405) suggests that a clinic is capable of being the recipient of health care supplies from a medical practitioner, notwithstanding the payment by the provincial insurance regime of the medical practitioner rendering the services. ... Company A will re-supply points to Company B to be issued by Company B to retail customers upon earning points – or to independent dealers to be issued to retail customers of those dealers. ...