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Administrative Policy summary

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress -- summary under Article 4

14 May 2019 IFA Conference Stephanie Smith on MLI MLI Progress-- summary under Article 4 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 4 post MLI, most of Canada’s treaties will have a residence tie-breaker rule When the Notice of Ways and Means motion for the implementation of MLI was tabled, Canada indicated that it would adopt additional provisions of the MLI including the tie-breaker rule for dual-resident entities. ...
Administrative Policy summary

15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations” -- summary under Subsection 95(8)

15 May 2019 IFA Finance Roundtable “Tracking Interest Rules & Umbrella Corporations”-- summary under Subsection 95(8) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(8) Finance has issued a comfort letter respecting umbrella corporation interests where there is no tax avoidance purpose It is not clear to Finance that the compliance burden on a Canadian investor under the tracking interest rules is unusually onerous compared with other compliance obligations under this part of the Act. ...
Administrative Policy summary

Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)". -- summary under Subsection 127(11.4)

Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)".-- summary under Subsection 127(11.4) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(11.4) ...
QCSC decision

. - Minister of National Revenue v. Samuel M. Ogulnik & Co. LTD, [1928-34] CTC 270

.- Minister of National Revenue v. Samuel M. Ogulnik & Co. LTD, [1928-34] CTC 270 MARTINEAU, J. ... It has been held that the making of wearing apparel by machines driven by electric power is " a manufacturing purpose. Idem Note 1. ... No doubt, speaking in the broadest sense, a 4 manufacturer is one who makes or fabricates anything for use, and that within the literal definition of manufacturer’ would come a tailor who works cloths into suits for wear. ...
Current CRA website

Appendix D – Daily meal rates at locations abroad – effective October 2018 to December 2018

Note: One rate for country Antarctica * * * * 17.50 CAD * Antigua and Barbuda Currency: US dollar (USD). ... Note: One rate for country Ponta Delgada * * * * 17.50 CAD * Bahamas Currency: US dollar (USD). ... Note: One rate for country Stanley * * * * 17.50 CAD * Fiji Currency: Fiji dollar (FJD). ...
Conference summary

25 November 2012 Roundtable, 2013-0479401C6 F - Employés et Achat Ltée – commentaires panel ARC -- summary under Paragraph 251(1)(c)

25 November 2012 Roundtable, 2013-0479401C6 F- Employés et Achat Ltée – commentaires panel ARC-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Buyco that is formed by employer to purchases departing employees’ shares is NAL In order to facilitate the disposition of shares of departing employees who had purchased their shares under an employee share ownership plan (ESOP), Opco forms and injects funds into a new company (Buyco), which uses those funds to purchase the employee’s Opco shares. ... This is consistent with 2007-0243171C6, 2002-0166655 and 2004-0103061E5 Petro-Canada and RMM …. ...
TCC (summary)

Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- summary under Payment & Receipt

The King, 2024 TCC 1 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt salary paid into her husband’s bank account was constructively received by the employee The appellant, a real estate brokerage firm, determined (based on agreement between its two employees) that the remuneration paid to them would be allocated as to $165,000 and $192,000 to Mrs. and Mr. ... Moreover, an amount of money is deemed received by an employee when it is available to the employee. [C]onstructive receipt applies with respect to Mrs. ...
Administrative Policy summary

14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT -- summary under Article 7(1)

14 May 2019 IFA Conference Stephanie Smith on MLI GAAR and PPT-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) PPT applied 1st like any other Treaty benefit limitation rule, any remaining benefit subject to GAAR scrutiny Question: How to the GAAR and PPT interact? ... S. 4.1 of the ITCIA provides that “notwithstanding the provisions of a Convention the GAAR, applies to any benefit provided under the Convention.” ...
Administrative Policy summary

3 November 1995 Interpretation 950229 – Sale of Rebuilt Cottage – ITCs on Costs Incurred for Rebuilding the Cottage -- summary under Section 192

3 November 1995 Interpretation 950229 Sale of Rebuilt Cottage ITCs on Costs Incurred for Rebuilding the Cottage-- summary under Section 192 Summary Under Tax Topics- Excise Tax Act- Section 192 rebuilding of fire-damaged cottage The subject cottage, that was rented out as a principal place of residence (ie., a residential complex) was subject to a fire in early 1995 that almost destroyed it. ...
Administrative Policy summary

IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993 -- summary under Subsection 147(10.1)

IT-363R2 (Cancelled) Deferred Profit Sharing Plans Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993-- summary under Subsection 147(10.1) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(10.1) 14. ...

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