Search - 微信撤回和删除的区别 官方

BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design – e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized – there may be some big changes coming out of that. ... We do not necessarily see that as the case – our penalty regime is based on reasonable efforts. ...

Email this Content 26 November 2013 Annual CTF Roundtable Q. 1 ("Pre-ruling consultations") Notes from Presentation Q. 2 ("Upstream loans") Q. 2(a) – Repayment of upstream loans Notes from Presentation Official Response Q. 2(b)(i) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 2(b)(ii) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 3 ("CAE Inc. ... Q. 4(b) – T1135/T1134 – No e-filing/ T1135-extension of normal reassessment period Notes from Presentation Electronic filing of T1134s and T1135s has not yet arrived. ... The obligations — much like needed repairs to property — are a future cost embedded in the forest tenure that serves to depress the tenure’s value at the time of sale. ...

Email this Content 2020 IFA-YIN Seminar on COVID-19 Guidelines Q.1 — Whether "Travel Restrictions" Must Be Enforceable Q.2 — Meaning of "Solely as a Result" Q.3 — Individual Not Ordinarily Resident in Canada Q.4 — Non-Resident Employers Q.5 — Directors Forced to Stay in Canada Q.6 — Location of Board Meetings Q.7 — Applicability to Residence in Other Jurisdictions Q.8 — Competent Authority Tie-Breaker Rule Q.9 — Non-Treaty Countries Q.10 — Non-resident corporation's return obligation Q.11 — S. 253(b) test during COVID Q.12 — TPM-17 and COVID government assistance Q.13 — Contacting CRA Q.14 — Waiver and Clearance Certificates Q.15 — CEWS and bad debts/discounts Q.16 — Convertible debentures Q.17 — Cameco This summarizes CRA responses at a webinar hosted by the International Fiscal Association (Canadian Branch) on 6 August 2020 (a Young Members Event). ... Would the presence of an employee in Canada — with or without the approval of their employer — be a situation in which the employer is considered to be carrying on business in Canada pursuant to paragraph 253(b) of the ITA? ... Q.16 — Convertible debentures Is there any update on the CRA’s administrative position on convertible debt as expressed in 2013-0509061C6 Part XIII Tax & Standard Convertible Debentures? ...

Delayed interpretation requests and related assessments Question CRA Response Q.30- Non-residents and permanent establishments Facts / Background Questions CRA Response Q.31- Update on audit issues and discussion Question CRA Response GST/HST audits and examinations enhancements Pre-assessment reviews Recaptured Input Tax Credits Q.32- Update on court cases/objection and discussion Facts/Background Question CRA Response Supplementary Questions Q.1- Treatment of general partner distributions Facts / Background Question CRA Response Q.2- Section 259 of the Excise Tax Act Facts / Background Questions CRA Response Q.3- HST- Conferences Facts / Background Questions CRA Response Q. 4 and 5 Supplies of Admissions Supplies of Real Property (i.e., Booth Space) Supplies of Other Personal Property and Services (e.g., Related Convention Supplies) Sponsorships of Events Q.6 and 7 Q.8 Q.4- RRSP’S / RRIF’S / RESP’S and the SLFI regulations Facts/Background CRA Response Q.5- Incorrect accounting for HST versus QST Facts / Background Questions CRA Response Q.6- Master trusts and the new pension rules Question CRA Response Q.7- Pension plan rules – deemed supplies – provincial factor- contribution – regular and special payment Facts/Background Question CRA Response Q.8- Calcualtion of the SAM – Hybrid pension plans Question CRA Response Q.9- Public sector body pension plans and the HST deemed supply rules Question A-1 Question A- 2 CRA Response A-1 CRA Response A- 2 Question B-1 Charity and public institution CRA Response Question B – 1 Charity Question B – 2 Charity CRA Response B- 2 Charity Question B – 3 Charity: CRA Response B – 3 Charity Question B – 1 Public Institution CRA Response B-1 Public Institution Question B – 2 Public Institution CRA Response B – 2 Public Institution Question B – 3 Public Institution CRA Response B – 3 Public Institution DISCLAIMER These comments do not replace the law found in the Excise Tax Act (the Act) and its Regulations. ... Q.6- Place of supply rules – section 182 damage payments Facts / Background A Co and B Co are both resident in Canada and registered for GST/HST purposes. ... Q.21- Residency of investment vehicles (LPs AND trusts) & zero-rating of investment management services Facts / Background Services that are supplied to a non-resident are generally zero-rated. ...

Email this Content 26 February 2009 CBA Roundtable Q.1- Lease Subsidy Payments By Non-Resident Manufacturer To Canadian Lessor Facts / Background Question Reasons in Support of Zero-Rating CRA Comments Q.2- Constructive Importer Rules And Section 180 Exclusion Facts / Background Question CRA Comments Q.3- Assignment Of Employment Contracts & Reverse Payment Facts / Background Question CRA Comments Q.4- Wash Transaction Assessment That Is Subsequently Overturned Facts / Background Question CRA Comments Step 1. ... Credit Note / Refund to customers Alternative Reassessment Waiver of Interest Q.5- Section 167 Election On Dissolution Of Partnership Facts / Background Question CRA Comments Q.6- Drop Shipment/Gst Memoranda Series 3.3.1 Q.7- Zero-Rating Of Financial Services Facts / Background Question CRA Comments Q.8- Gst Registration & T2 Returns Facts / Background Question Q.9- Special Investigation Facts / Background Question CRA Comments Q.10- Bad Debts Facts / Background Question CRA Comments Q.11- Gst Treatment Of Payments On Behalf Of Co-Owners Facts / Background Question CRA Comments Q.12- Section 186 Input Tax Credit Entitlement Facts / Background Question CRA Comments Q.13- Deemed Financial Institution Facts / Background Question Discussion CRA Comments Q.14- Dealing With Taxpayer Representatives Facts / Background Question CRA Comments Facts / Background Question CRA Comments Q.15- S. 167- Availability Of Election. ... Rental Use Facts / Background Question CRA Comments Q.28- Electronic Coupons, Points, And The Meaning Of “Fixed Dollar Amount” Facts / Background Questions CRA Comments Q.29- Section 144.01 Of The Excise Tax Act Facts / Background Question CRA Comments Q.30- Rebate Documentary Requirements Facts / Background Questions CRA Comments Q.31- Reporting Gst On Residential Real Estate Transactions – Interplay Between Eta Section 194 And Subsection 221(2) Facts / Background Questions CRA Comments Q.32- Retroactive Deregistration Facts / Background Question CRA Comments Q.33- Subsection 182(1) Facts / Background Question CRA Comments Q.34- Canadian Supplier Facts / Background Question CRA Comments Q.35- Gst Registration Procedures Facts / Background Question CRA Comments Q.36- Eta 169(4) Documentation Facts / Background Question CRA Comments Q.37- Documentation To Justify The Transfert Price Facts / Background Question Facts / Background Question CRA Comments Q.38- Canadian Auctioneer Facts / Background Questions CRA Comments Q.39- Emphyteusis Facts / Background Question 1 CRA Comments Question 2 CRA Comments Q.40- Update By Appeals Branch CRA Comments 41. ...

Email this Content 29 May 2018 STEP Roundtable Q.1 — Update on the Dedicated Telephone Service Preliminary Response Official response Q.2 — Creation of a Trust Preliminary Response Official response Q.3 — Trust return due date in the year of wind up Preliminary Response Official response Q.4 — Safe Income and an Estate Preliminary Response Official response Q.5 — Split Income Proposals- Definitions Preliminary Response Official response Q.6 — Split Income Proposals- Holding company qualifying as "excluded share" Preliminary Response Official response Q.7 — Split Income Proposals- Excluded shares and business income Preliminary Response Official response Q.8 — Subsection 70(5) Preliminary Response Official response Q.9 — Requirements for a trust to have all interests in the trust vest indefeasibly Preliminary Response Official response Q.10 — Pipeline Rulings Preliminary Response Official response Q.11 — Trusts subject to subsection 104(13.4) in year of death of the trust's primary beneficiary Preliminary Response Official response Q.12 — U.S. ... The test in proposed s. 120.4(1) – “excluded shares” – (a)(i) is that business income be less than 90% from the provision of services. ... Preliminary Response Phil Kohnen: In s. 108(1) – “trust” – (g), there is an exception to, among other things, the 21-year deemed disposition rule in s. 104(4). ...

Email this Content 21 November 2017 CTF Annual Conference Roundtable Q.1 – S. 107(2) distribution by resident trust to Canco owned by non-resident Preliminary response Official response Q.2 – Trusts and principal residence exemption Preliminary response Official response Q.3 – S. 55(2.1) “purpose” CRA response- Background Q.3(a) Purpose v. result Preliminary response Q.3(b) Objective v. subjective Preliminary response Official response Q.4 – S. 55(2) – Timing of deemed capital gain Q.4(a) Timing of gain Q.4(b) CDA Preliminary response Official response Q.5 – Interaction of ss. 55(5)(f) and 55(2.3) with s. 55(2.1) Q.5(a) Separate test Preliminary response Q.5(b) Stock dividend Preliminary response Official response Q.6 – Circular Pt. IV/55(2) calculations Preliminary response Official response Q.7 – CRA Folios update Preliminary response Official response Q.8 – MLI “principal purpose test” Q.8(a) GAAR Committee Preliminary response Q.8(b) PPT/GAAR Preliminary response Q.8(c) GAAR jurisprudence Preliminary response Q.8(d) OECD examples Preliminary response Official response Q.9 – Stock option deduction Preliminary response Official response Q.10 – Tax shelter rulings Preliminary response Official response Q.11 – Application of Art. ... This is not a new position – I refer you to 2012-0440191R3. Official response 21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters Q.11 – Application of Art. ...

Email this Content 25 November 2021 CTF Roundtable Q.1 – Indemnities and Subsection 87(4) Preliminary Response Scenario 1 Scenario 2 Scenario 3 Scenario 4 Official Response Q.2 – Subsection 15(2) Shareholder Loans and TOSI Preliminary Response Official Response Q.3 – Section 86.1 Preliminary Response Official Response Q.4 – “Liable to Tax” and Territorial Taxation Preliminary Response Official Response Q.5 – Corporate Attribution in a Tiered Corporate Structure Preliminary Response Official Response Q.6 – Subsection 143.4(1) and the “right to reduce” Preliminary Response Official Response Q.7 – Sub-funds and the Tracking Interest Rules Preliminary Response Scenario 1 Scenario 2 Official Response Q.8 – Loan from a FA to a Partnership held by two FAs Preliminary Response Official Response Q.9 – Work-Space-in-the-Home Expenses Preliminary Response Official Response Q.10 – Regulation 100(4)(a) and Payroll Deductions and Remittances Preliminary Response Official Response Q.11-Subsection 261(21), Loan to FA and Excluded Property Preliminary Response Official Response Q.12 – Remission Orders and Fees Preliminary Response Official Response Q.13 – Income Tax Rulings Directorate Preliminary Response Official Response Q.14 – Failure to Properly File a T1135 and Section 233. ... S. 95(8) always turns on the pool of property – referred to as the “tracked property and activities.” ... The courts have also found that there must be a link between the money that was borrowed and the current use – the “current use approach.” ...

Email this Content 25 September 2017 CTF Finance Roundtable on 18 July 2017 Proposals Passive Income Q.1 – Effect on lower-bracket taxpayers Oral Response Q.2 – Calculating deferral on investment income Oral Response Q.3 – Principles affecting the proposals Oral Response Q.4- Grandfathering Oral Response Income-Sprinkling Q.5 – Complexity of TOSI Oral Response Q.6 – Difference in treatment of family transactions Oral Response Q.7 – Comparison of friends in business vs. family members Oral Response Surplus-Stripping Q.8 – Pipeline transactions Oral Response Q.9 – Effects on intergenerational transfers of family businesses Oral Response Q.10 – Scope of s. 246.1 Oral Response Q.11 – Non-ancillary s. 246.1 application to NAL transactions Oral Response General Q.12 – Implementation Oral Response Additional comment on tax advantage computation This summarizes the oral responses provided by two senior Finance officials at the Finance Roundtable held at the Infinity Convention Centre in Ottawa on 25 September 2017. ... I do not know precisely how the legislative proposals – I’ll focus on income sprinkling for the moment – will go forward – that is to say whether the next step is another draft, tabling, or something else. ... There is also the longer term – not years, but more than the next couple of weeks or months – where we need to consider whether to add exceptions or refinements to the rules. ...

The Queen Facts / Background Question CRA Comments Q.4- Real Proeprty Transactions: Liability To Remit Gst Facts / Background Analysis Question CRA Comments Q.5- Small Supplier Threshold: Multiple Owners of Bed & Breakfast Facts / Background Question CRA Comments Q.6- Nursing Homes Facts / Background Questions CRA Comments Q.7- 191(3) And Itcs Facts / Background Question CRA Comments B. ... The basic tax content was: (A- B) × C = ($7,000- 0) × the lesser of 1 and ($50,000/$100,000) = $3,500 In December 2003, the commercial use of the property decreased to 35%. ... Under ETA 200 (2), ABC was deemed to have collected GST equal to the basic tax content, which was: (A- B) × C = ($3,500- 0) × the lesser of 1 and ($50,000/?) ...