Search - 广东省2025政府工作报告 一小发展 金句

14 July 2025- 11:28pm We have translated 8 more CRA interpretations Email this Content We have translated two CRA interpretations released last week and a further 6 CRA interpretations released in June of 2000. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-09 26 February 2025 Internal T.I. 2023-0985151I7 F- Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense contingent dividend prospect likely did not support a deduction for an obligation to reimburse legal fees Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible Income Tax Act- Section 42- Subsection 42(1)- Paragraph 42(1)(b)- Subparagraph 42(1)(b)(ii) s. 42(1)(b)(ii) might apply to the vendor’s agreed reimbursement, post-sale, of the sold corporation’s legal costs of a failed suit 22 May 2024 External T.I. 2024-1016211E5 F- Mineral Resource Cert- XXXXXXXXXX Income Tax Act- Section 248- Subsection 248(1)- Mineral Resource- Paragraph (d)- Subparagraph (d)(i) NRC certification received 2000-06-09 11 May 2000 External T.I. 2000-0009605 F- Démolition d'un immeuble Income Tax Regulations- Regulation 1100- Subsection 1100(11) Reg.1100(11) does not limit a terminal loss Income Tax Act- Section 20- Subsection 20(16) rental property restriction rule does not apply to a terminal loss Income Tax Act- Section 13- Subsection 13(21.2) s. 13(21.2) does not apply to an individual nor to a corporation demolishing a building while retaining the land for more than 30 days Income Tax Act- Section 54- Superficial Loss no superficial loss where demolition of building Income Tax Act- Section 40- Subsection 40(3.3) no suspended loss where demolition of building 15 May 2000 External T.I. 2000-0001995 F- CONGE SANS SOLDE-REGIME DISTINCT Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) payment of premiums by employee during unpaid leave did not create a separate plan, so that any benefits received would still be taxable 11 May 2000 Internal T.I. 2000-0008270 F- Perte finale disposition bâtiment Income Tax Act- Section 13- Subsection 13(21.1)- Paragraph 13(21.1)(b) s. 13(21.1)(b) would apply to reduce terminal loss even if the land was disposed of at a loss in a previous year 24 May 2000 Internal T.I. 2000-0017677 F- PENSION ALIMENTAIRE Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount payments made pursuant to a separation agreement in order to maintain a financial balance between them rather than for maintenance, were not support amounts 17 May 2000 External T.I. 1999-0011695 F- Revenu protégé- options et dividendes follow-up in 2000-0040405 F Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income of Pubco allocated to option granted to a minority shareholder to acquire its shares, but reduced by Pubco dividends 17 March 2000 APFF Roundtable Q. 11, 2000-0008260 F- DEDUCTION POUR PLACEMENTS Income Tax Act- Section 181.2- Subsection 181.2(4)- Paragraph 181.2(4)(b) balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances” ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). CRA has now announced that this arrangement is revoked effective for any fiscal year of a dentist (who had been relying on this arrangement) that begins on or after January 1, 2025. ...

12 January 2025- 11:10pm CRA confirms that an individual can claim unclaimed donations made by her spouse before marriage (going 5 years’ back), including maybe for statute-barred years Email this Content CRA confirmed that an individual could claim (in years in which she was married, within the 5-year carryforward period from the year of the donation) the portions of a charitable donation that her husband had made before they had married, but which he had not claimed (perhaps, because of his limited income). ... Summaries of 5 September 2024 External T.I. 2024-1022711E5 under s. 118.1(1) – total charitable gifts- (c)(i)(A) and s. 152(4.2). ...

19 January 2025- 11:28pm CRA rules on a two-wing split-up net asset butterfly Email this Content CRA ruled on a straightforward split-up butterfly. ... Summary of 2024 Ruling 2024-1008821R3 F under s. 55(1) – distribution. ...

17 March 2025- 11:36pm CRA rules on a single-wing butterfly of a DC held by two families’ Holdcos, with DC then amalgamated with one of the Holdcos Email this Content CRA ruled on a relatively straightforward single-wing butterfly spin-off of a proportionate part of its assets (on a net FMV basis) of a portfolio investment company (DC) held (mostly indirectly) by two sisters (A and B) and B’s children. ... Summary of 2022 Ruling 2021-0911791R3 F under s. 55(1) – distribution. ...

13 April 2025- 11:25pm CRA rules on a split-up butterfly between a divorced couple where excess debt is allocated to land rather than building to produce capital gains treatment Email this Content In order to accomplish a multi-wing split-up net asset butterfly of a private corporation (DC) owned by a divorced couple, they will transfer their common shares of DC to two new transferee corporations (TC1 and TC2), then DC will distribute each of the two rental properties, along with cash assets, to the respective TC in consideration for the assumption of liabilities (including shareholder advances and mortgage debt) and the issuance of TC preferred shares. ... Summary of 2024 Ruling 2023-0998291R3 F under s. 55(1) – distribution. ...

27 July 2025- 11:32pm CRA agrees that the concept of reporting platform operators collecting “business registration numbers” from Canadian-resident sellers is inapplicable Email this Content S. 284(2) requires (digital) reporting platform operators (RPO) to collect a taxpayer identification number (TIN) and a business registration number (BRN) in respect of a seller other than an excluded seller. ... Although the provinces may issue BRNs, Canada does not – hence the conclusion. ...

13 August 2025- 12:29am CRA confirms T4A slip requirements and the potential for penalties Email this Content Regarding a non-profit corporation operating a youth baseball league in Ontario which was paying fees to independent contractors for their services of officiating at the games, CRA noted that its administrative exception from the T4A slip requirement for services fees of less than $500 per year, and for services rendered to individuals by professionals or for repairs or maintenance of an individual’s principal residence, did not apply, so that T4As were required CRA indicated that the late-filing penalties under ss. 162(7.01) and (7.02) could apply cumulatively for failure to file the T4As; and also seemed to imply that the $2500 penalty under s. 162(7)(a) could apply (which seems incorrect – it does not apply if s. 162(7.01) or (7.02) applies). ...