Search - 报销 发票日期 消费日期不一致

Our view is supported by the … Explanatory Notes …. Therefore … since it has been assumed that Mrs. ...

. … … [I]t cannot be considered … that the amounts payable by Corporation B and/or Corporation C under the second contract could represent consideration for the use of an amount of capital (or a right to the amount of capital). … [In addition t]he contractual relationship between Corporation A and Corporation B, on the one hand, and Corporation A and Corporation C, on the other hand, … does not appear to us to create a lender-borrower relationship between those corporations, so that subparagraph 20(1)(c)(i) cannot be applicable. ...

This interpretation is consistent with [9422630] …. Since … the trust indenture indicates that the trustees shall act in a manner that promotes or supports the purposes for which the trust was created, the granting of annuity contracts by the trust is part of a strategy to increase its gift income and enable it to achieve its purposes, even though the trust indenture contains no specific reference to the provision of such annuity contracts. … [T]herefore … subsection 75(2) applies …. ...

7 October 2022 APFF Roundtable Q. 11, 2022-0942751C6 F- Changement de fin d'exercice et opposition-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) CRA will not vacate an assessment that was not invalid or unfounded 2020-0874951I7 indicated that if a request for a retroactive change to a taxation year is made after the corporate tax returns are filed but before the first Notice of Assessment for that year is issued, it will generally be granted – but not if such request is made after such issuance. ... In rejecting this approach, CRA stated: For the purposes of subsection 165(3), an assessment may generally be vacated upon receipt of a Notice of Objection if a taxpayer submits additional facts or compelling arguments that were not before the Minister at the time the assessment was made and that demonstrate that the assessment is either invalid … or was unfounded …. [Here] … the mere fact that the corporation wishes to change the timing of its fiscal period end after tax has been assessed for the year corresponding to the fiscal period, even if it is the corporation's first fiscal period, does not, in and of itself, invalidate or render unfounded the [initial] assessment …. ...

Preliminarily to this spin-off, an indirect Canadian subsidiary of Foreign Pubco (Canco – which is the distributing corporation) will transfer the Canadian business relating to Business B as well as related foreign subsidiaries held directly (Forsub) or through a partnership (Forlp) and a partner thereof (Canco Sub 4) to the transferee corporation (TCo – a ULC). ... TCo (through transactions which are heavily redacted – see perhaps para. 122) will be indirectly transferred to Foreign Pubco, whereas Canco will become an indirect subsidiary of Foreign Spinco. Indemnity – effect on net value of types of property In order to accomplish the butterfly spin-off of Canco's portion of Business B, Canco will first transfer such assets to Newsub under s. 85(1). ...

CCRA noted that “[s]everal court cases, including … Benjamin … 54 DTC 357 … have determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer and therefore not deductible pursuant to paragraph 18(1)(h).” ...

The second fund is … a "NISA Fund No. 2 " …. Generally, a taxpayer must include in computing income for a taxation year from property by virtue of subsection 12(10.2) the total of all amounts paid to the taxpayer from the taxpayer's NISA Fund No. 2. ...

The Directorate concluded that “ it would be difficult to argue that the distributions made by the trustee which are stated to be capital distributions in the memoranda of decisions … are required to be included in [her] income under subsection 104(13).” Before so concluding, the Directorate stated: [T]he trustee of a discretionary trust can normally choose whether to make a certain payment out of income or out of capital- at least, to the extent of the trust's income and capital. … In this case, [the resident beneficiary] is both an income beneficiary and a capital beneficiary and can receive either income or capital distributions in any taxation year. However, the trustee cannot change the true nature of an income distribution by merely considering it to be a capital distribution. … As stated in … 2000-0043847 … the amount of income to be included in a beneficiary's income under subsection 104(13) is the amount of the trust's income for tax purposes that has been distributed to the beneficiary. ...

The Directorate stated: [T]he term “reasonably attributable” … denotes … a direct causal connection … between the OCNP and the PE taking in account all the applicable facts of the case. … [Per] E9807035 … the taxpayer should attribute a portion of its gross revenues to each permanent establishment in recognition of the value of the ancillary services provided by that establishment. … [W]here a taxpayer has made an allocation under subsection 403(4) and the taxpayer’s approach is reasonable, the CRA should not require the taxpayer to use a different method of allocation. … [T]he allocation of the OCNP based on where the policies are underwritten … appears to be a reasonable method. Similarly, allocation of the OCNP on some other basis, such as where the contracts are negotiated or serviced … may also be reasonable …. ...

31 August 2000 External T.I. 2000-0035675 F- INSTITUT DE RECHERCHE AGRÉÉ-- summary under Clause 37(1)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(B) CCRA requires that a hospital research institute be separate from the hospital In explaining its refusal to accredit an organization, CCRA stated: [A]n organization that provides hospital services and carries out joint scientific research and experimental development (SR&ED) will not come within clause 37(1)(a)(ii)(B) or clause 37(1)(a)(ii)(A) since … the organization does not carry on SR&ED activities only. … CCRA … requires that a hospital's research centre be a legal entity separate from the hospital …. ...