Search - 报销 发票日期 消费日期不一致

. … As indicated in paragraph 2.58 of … S1-F3-C2 … paragraph 45(1)(c) applies where the partial change in use of the property is substantial and of a more permanent nature. ...

CRA responded: Question 1 – Broad class of persons The phrase “a broad class of persons” … would generally encompass a large group of persons dealing with a financial institution at arm’s length who have been offered the same incentive without regard to tax considerations or their other personal or financial circumstances. … For example, an incentive offered by a financial institution to all clients who invest or maintain registered and non-registered accounts at a specific minimum dollar amount would generally be considered to be offered to a broad class of persons. … [W]hether an incentive offered only to a “select group” of clients would qualify for the exception would depend on the size of the group relative to the financial institution’s client base as a whole as well as on the particular criteria used to select eligible investors. ... Question 2 – Commercially reasonable In general terms, we consider reasonable incentive programs of the type frequently offered by financial institutions, such as moderate fee rebates or bonus interest payments, to be offered in a “normal commercial or investment context” in which parties deal with each other at arm’s length and act prudently, knowledgeably and willingly (described in this letter as commercially reasonable). … [F]actors indicating that an incentive program is not commercially reasonable would include disproportionate benefits relative to investment size, parties acting in concert and other commercially unreasonable behaviour that suggests a main purpose of the arrangement is to allow the investor to benefit from the registered plan’s tax exemption. Question 3 – Monetary value of incentive We consider the value of the incentive relative to the amount invested to be a significant factor in determining if an incentive program is commercially reasonable. ...

17 April 2001 External T.I. 2001-0074915 F- Fonds commun de placement- Disposition-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition change in taxable account through which MFT units are held does not entail their disposition Regarding whether there is a disposition when a taxpayer transfers mutual fund units held in a taxable account with one financial institution to taxable account at another financial institution, so that there is a change in the administrator, CCRA stated: To the extent that a change in the administrator of an account in which mutual fund units are held does not entitle the owner of such units to proceeds of disposition of property and does not result in a change in the beneficial ownership of such units … such a change generally does not constitute a … “disposition” …. ...

We consider that the following factors would be relevant in making such determination: • the identity of members, • the structure of the corporation, • who exercises control over the financing, operation and direction of the corporation, • who has the right to elect or change the board of directors or to reverse its decision, • who can contribute capital and receive a distribution of capital, • details regarding asset distribution on winding-up or dissolution and • whether a person other than her Majesty in right of Canada, a province or a Canadian municipality has any right to acquire any capital of the corporation. ...

The corporation no longer needs the policy on the executive’s retirement, and it transfers the policy to him for no consideration at a time when the particulars are: Death benefit $1,000,000 Cash surrender value $ 125,000 Adjusted cost basis $ 50,000 Fair market value $ 125,000 Without being queried on this issue, CRA stated: Although there are certain exceptions in the "advantage" definition, a benefit arising from the RCA holding a life insurance policy is not among them. ...

. … [W]e do not know whether the compensation paid for the Internet fees represents an allowance or a reimbursement of actual expenses incurred. … If it is … a reimbursement of actual expenses … [and] the facts show that this Internet access is essential for the employees to perform their employment duties, we are of the view that it is unlikely that a significant taxable benefit will result to the employees from the reimbursement of the Internet and modem fees. In such a case, the reimbursement would not be included in employment income. … [S]upplies [under s. 8(1)(i)](iii)] would not include the cost of tools or equipment or amounts paid for a cell phone connection or communication licence fee. ...

5 October 2018 APFF Roundtable Q. 9, 2018-0768801C6 F- Tax on Split-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (a)- Subparagraph (a)(i) portfolio investment company might qualify as having a business 2018 STEP Roundtable Q.6 and Q.7 confirmed that the shares of a holding company (or of a company generating no business income) cannot qualify as excluded shares, whereas Examples 8 to 12 of CRA’s “ Guidance on the application of the split income rules for adults ” and the Department of Finance’s “ Technical Backgrounder on Measures to Address Income Sprinkling ” provide that such shares so qualify. ... CRA stated: The CRA's response to [Q.7] …was based on the assumption made in the statement of that question that the corporation had no business income. … …[In its Guidance] … to demonstrate that the various exclusions were applicable … to entities carrying on a business whose principal purpose is to derive income from property, including interest, dividends, rents and royalties, such as investment management corporations (in Examples 8 and 12), the CRA assumed that these corporations maintained a sufficient level of activity such that their income could be considered as derived from such a business. ... X, her shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends … notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...

After finding that such amounts were not a reserve described in s. 181.2(3)(c), and in finding that they were includible in taxable capital pursuant to s. 181.2(3)(b) as “advances,” the Directorate stated: The word "advance" … denotes, inter alia, the lending of money or the payment of an amount against the price of a contract for services or goods, paid before the contract is performed, the services rendered or the goods delivered. … [I]n this context … the consideration to be received by customers is … the XXXXXXXXXX service offered by the corporation. ...

CRA responded: In general, a request for a revision to capital cost allowance claimed on property held by a partnership may be granted if all the conditions in paragraph 10 of … IC84-1... are satisfied by all members of the partnership. ... Such request will not be allowed … where … the Minister has issued a notice of determination … to one or more members. ...

19 November 2009 External T.I. 2007-0257251E5 F- Assurance-vie-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) benefit where sub is policyholder and premium payer and parent is beneficiary – but not for reverse The parent corporation is the beneficiary of a life insurance policy while its subsidiary is the policyholder and pays the premiums. ... The above interpretation represents a change in position from …. 2004-006546 … and will apply as of calendar year 2010. … [W]here a parent corporation pays the premiums for a life insurance policy that it owns and of which the subsidiary is a beneficiary, there is no benefit to the shareholder under subsection 15(1). ...