Search - 微信撤回和删除的区别 官方

CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ...

. … Given the fact that a non-resident that receives a letter containing proposed assessed amounts would almost certainly make a valid paragraph 94(3)(f) election before an audit assessment is actually issued, it appears unlikely that such a non-resident would ever be prevented from making a valid election. ...

13 April 2023 External T.I. 2017-0684341E5 F- Perte au titre d’un placement d’entreprise-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) active business for SBC purposes can continue after regular business operations have ceased/ sale of debt for $1 to unrelated purchasers might be a non-arm’s length transaction An individual was the sole shareholder, and held an interest-bearing debt (the "Debt" – acquired for an income-producing purpose), of a corporation operating a restaurant which in 20X1 sued the franchisor at the same time as closing the restaurant. ...

It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...

. … Even if a grant of full-value RSUs was related to past services, it is also still possible that those past services were rendered solely in the Grant Year. ...

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

The unwinding of the above loss consolidation arrangements will entail inter alia Newco redeeming its preferred shares with a note, which New LP will use to repay the New LP Loan by assigning it to Parent, with that note then being set off against the Parent Loan – and Newco and New LP being wound up. ...

After noting that “on July 22, 2022, the Minister of Crown-Indigenous Relations announced that the section 87 tax exemption would be available for continuation on modern treaty governments’ former reserves and other First Nations reserves in Canada for prospective and existing modern treaty government beneficiaries who are registered or entitled to be registered under the Indian Act ”, CRA stated: [W]e agree with updating the Guidelines to allow modern treaty governments or organizations controlled by modern treaty governments to be eligible employers under Guideline 4. ...

4 June 2024 STEP Roundtable Q. 8, 2024-1007841C6- Disposition of Property Held in a Bare Trust-- summary under Subparagraph 150(1.1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.1)- Paragraph 150(1.1)(b)- Subparagraph 150(1.1)(b)(ii) a disposition by a bare trust, or the trust’s winding-up, generally is not a disposition under the ITA A bare trust (not described in (a) to (e.1) of s. 108(1) – trust) holds no property in the year other than a Cdn.$10,000 government bond and money, not exceeding Cdn.$50,000 in the year, so that it satisfies s. 150(1.2)(b). ...

Although the ordinarily-inhabited condition under the principal residence definition would not generally be met for the Secondary Suite while being rented to third parties, where it was subject to the s. 45(2) election it could nonetheless qualify as the taxpayer’s principal residence for up to four taxation years during which the election remained in effect – so that the homeowner would be able to choose for such a year to designate the Secondary Suite rather than the balance of the property as that taxpayer’s principal residence. ...