Search - 微信撤回和删除的区别 官方

. … The fact that a trustee guarantees bank loans made to the trust does not, in itself, give rise to the application of the provisions of subsection 75(2). ...

After finding that this credit was not required to be included in income under s. 12(1)(x.2), CRA noted that it: has taken the position in the past that the RDCL does not reduce cumulative Canadian exploration expenses ("CCEE") and cumulative Canadian development expenses ("CCDE"), on the basis that the RDCL was too remote from the Canadian exploration expense ("CEE") and Canadian development expense ("CDE") and therefore did not have a sufficiently direct connection to the CEE and CDE incurred by the particular corporation to fall within element J of the definition of CCEE in subsection 66.1(6) and the description of M in the definition of CCDE in subsection 66.2(5) …. ...

. … The fact of incurring a loss is the only real condition to be satisfied in order to claim an RDCL amount. ...

. … Subsection 98(1) will not apply where, the affairs of a partnership are wound up at any time during its usual fiscal period and all of the partnership's property is distributed prior to, or concurrently with, the winding-up. ...

. … [I]t seems difficult to argue that the parties intended to create a new contract. ...

. … Before finding that each of ss. 75(2)(a)(i) and (ii) and (b) applied, CRA stated: Given the settlor’s power to amend the trust and to remove any trustee, in our opinion the settlor is empowered in this case to unilaterally amend any provision of the trust indenture at their sole discretion. ...

CRA responded that in light of the amended s. 55(2)(c) wording and its understanding of the tax policy of s. 55(2), the amount deemed to be a gain under s. 55(2)(c) is deemed to be realized on the disposition of a capital property at the time of the payment of the dividend – for purposes of inclusion in income, but also for the purpose of the CDA definition. ...

21 November 2017 CTF Roundtable Q. 6, 2017-0724071C6- Circular calculations Part IV tax-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) refunded Pt IV tax payable not reduced by application of s. 55(2) Holdco receives a dividend of $400,000 that is subject to Part IV tax of $153,333 (38.33% of $400,000) equalling the connected payer’s dividend refund and, in turn, pays a dividend to its shareholders resulting in a refund of the Part IV tax – so that the dividend received by Holdco is subject to s. 55(2). ...

The Directorate then noted that as “the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement,” it followed that either individual could have de jure control and be related to the employer under s. 251(2)(b)(i). ...

. … [T]he word “income” in this section refers to “net income”. Accordingly, if expenses are disproportionately allocated when calculating the income described in subparagraph (a)(i) of the definition of SCI in subsection 125(7) for the year …[o]nly the expenses that are reasonable to consider to be attributable to the activities generating the income described in subparagraph (a)(i) of the definition of SCI should be considered. ...