Search - 报销 发票日期 消费日期不一致

CRA responded: As described in … S1-F2-C3 … 3.94 … materials related to the program includes the cost of items that are essential for the completion of the program and are expected to have a lifespan use generally limited to the program length, such as books, lab coats, brushes and paints. ...

A, Holdco A and Trust A sell ½. ½ and ¼, respectively, of their shares of Corporation A on a s. 85(1) rollover basis in exchange for similar-attribute shares of Newco. ...

Our position is supported by … Berkovic … 83 DTC 335 and …. Mitosinka …. ...

That is what the Tax Court of Canada indicated in … Ekamant … 2009 TCC 408 …. Thus … Corporation A did not become a CCPC at the time of the signing of the purchase offer made by Corporation B since it continued to be controlled by Pubco at that time. ...

Nevertheless, since it is clearly established in the collective agreement that travel expenses are to be paid by the employer, it is not possible to invoke the concept of tacit or implicit agreement as invoked in … Moore … and … Betz... [which] determined that travel was implicitly required as part of the taxpayers' employment in order to properly perform their duties and obtain a favourable performance appraisal. … ...

In finding that the partnership would not satisfy various requirements of IT-426R, para. 2 for use of the cost-recovery method, including the requirement of subpara. 2(e)- that “[t]he vendor submits, with his return of income for the year in which the shares were disposed of, a copy of the sale agreement”- CRA stated: … T5013 forms … do … not constitute a return of income for the purpose of [subpara. 2(e)] …. ...

17 April 2003 Internal T.I. 2003-0181507 F- PRET SANS INTERET-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) accessing the exceptional circumstances test requires demonstrating “a sufficient connection between the interest-free loan and an indirect source of the person's income” After surveying the jurisprudence on the exceptional circumstances test, the Directorate stated: Interest deductibility in other situations involving interest-free loans by a person to a corporation of which the person is not a shareholder may be justified on the particular facts of the case, as in Canadian Helicopters … and … Byram … to the extent that the person can show that there is a sufficient connection between the interest-free loan and an indirect source of the person's income. ...

For example: The RestaurantCo certificate offers discounts at […] locations in […] [Participating Province X]. ... The certificate has a value of over $[…] and is sold for $19.99. It has four components: A single use [dining] offer of a […]% discount on food total (maximum value $[…]) […] free dinner entrees: Buy one, get one […] free lunch entrees: Buy one, get one Purchaser will receive $[…] in RestaurantCo cash with every catered order over $[…] CRA rules that the certificates are not gift certificates for GST purposes, as they do not have a monetary value. ...

This principle has been invoked … [in] Burnco Industries … Wawang Forest … and Newfoundland Light …. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...