Search - 报销 发票日期 消费日期不一致

However, a foreign educational institution that is [so] listed … will be recognized as a "post-secondary educational institution" …. However, it is the RESP promoter's responsibility to ensure that educational assistance payments under the plan are made in accordance with the conditions of registration set out in paragraph 146.1(2)(g.1). … … If a promoter wishes to obtain confirmation that a foreign educational institution is recognized for the purposes of section 146.1, it may make a request to the following address: …. ...

Before noting that the distinction would cease to matter as a result of a proposed retroactive amendment to s. 14(1.01), the Directorate accepted that the agreements represented goodwill stating: [A] private institution under contract must also sign an operating agreement with the MSSS [Quebec Ministry] under which the institution undertakes to provide services as a CHSLD [care facility] …. In return, the MSSS provides the necessary funding for the operation of the institution. … [T]he operating agreements constitute goodwill … since the acquisition of one or more operating agreements by a purchaser can only be made if the Minister … has approved the assignment of the underlying licence. ... Thus, since the transfer of the operating agreements cannot be made without the transfer of the business to the new purchaser, we are of the view that the operating agreements constitute goodwill …. ...

Our understanding of your situation is that the estate has been terminated …. Since it cannot be reopened, the amount … was received directly by the heirs. In this case, it is the heirs who must include the amount so received … in computing their income pursuant to paragraph 56(1)(a). ...

. … Consequently, the amount of sales tax would not reduce the amount received from this plan, which is otherwise taxable. … [T]he payment of sales tax on wage-loss insurance premiums by the employer [would not] represent a contribution by the employer under the wage-loss insurance plan for the purposes of determining whether a wage-loss insurance plan is a plan to which an employer has contributed for the purposes of paragraph 6(1)(f). … [I]f the employee has a contractual or legal obligation to pay all wage-loss insurance premiums, the employer's payment of sales tax on such premiums would not make the benefits from the wage-loss insurance plan taxable. However … the employer's payment of sales tax on insurance premiums [is] a taxable benefit to the employee pursuant to paragraph 6(1)(a) …. ...

CRA responded: In general terms, the determination of whether an obligation has been disposed of for Canadian income tax purposes depends on whether these events are considered to result in the discharge of the obligation and the substitution of a new obligation under the law governing the former obligation …. Where the governing law is Canadian … making a RFR Amendment to an IBOR Instrument to accommodate the transition from IBOR to RFRs, in and of itself, would generally not constitute a disposition of the IBOR Instrument …. Where foreign law governs an obligation … the legal effect of these events on such an obligation under the relevant foreign law must be considered in order to determine if the obligation has been disposed of …. ...

7 October 2020 APFF Roundtable Q. 6, 2020-0852181C6 F- Par. 5(2)(b) of the Employment Insurance Act-- summary under Paragraph 5(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Employment Insurance Act- Section 5- Subsection 5(2)- Paragraph 5(2)(b) CRA now applies a “proportionate attribution approach” in applying the s. 5(2)(b) test of “control … of … voting shares” Équipements Boifor, 2019 CAF 69 concluded that two shareholders did not have insurable employment by virtue of s. 5(2)(b) of the EIA given that they controlled more than 40% of Boifor's shares, taking into account those individuals’ shares held indirectly through a holding corporation, even though the shares were held on a 50-50 basis and no one individually held control of the holding corporation. ... CRA responded: In light of the FCA's decision, the CRA must now consider the proportionate attribution approach in similar situations to determine whether the employment of a person who controls more than 40% of the voting shares of the employing corporation is insurable. … … The proportionate attribution approach leads to the conclusion that the two shareholders each control more than 40% of Opco's voting shares (50% of 100%) for the purposes of EIA paragraph 5(2)(b). … The approach remains the same where the shareholders held 51% and 49% of the voting shares of Holdco, respectively. ...

Aco will be able to deduct the portion of the periodic amounts of the consideration relating to the use of the property …. By contrast, the portion of the periodic amounts of the consideration relating to the acquisition of a purchase option on the Vehicle should be considered as expenditures of a capital nature for the acquisition of a capital property. … To the extent that Aco exercises its purchase option … Aco's cost of the Vehicle pursuant to subsection 49(3) will be the sum … paid in accordance with the exercise price … plus the adjusted cost base of the option, which will be the portion of the consideration paid that is attributable to the acquisition of that option. ...

Y would not constitute "split income" … [as it] is not an amount described in paragraphs 120.4(1)(a) to 120.4(1)(e) of the definition of "split income". There may, however, be abusive situations where the CRA would consider the use of the general anti-avoidance rule …. [f]or example … if it were found that the transactions were put in place to circumvent the application of the TOSI provisions. … Furthermore, it should be noted that the $400,000 allocated and distributed to Child Y by the family trust could, depending on the facts of the situation, constitute "split income" to Child Y …. ...

9 May 2022 Internal T.I. 2018-0790251I7- 45(2) election and beneficial ownership-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership a spouse could be the beneficial owner even though she did not contribute to the property's purchase / owner means beneficial owner S. 45(2) permits a taxpayer to elect to avoid a deemed disposition from a conversion of “property of the taxpayer” from personal to income-producing use. ... A person who has beneficial ownership but not legal ownership can enforce their ownership rights against the holder of legal title. … There is generally a presumption that the holder of legal title of a property is also the beneficial owner of the property, unless the facts support otherwise. It concluded: [I]f both spouses are considered to have beneficial ownership … they would both be required to file the election …. ...

. … There is no established principle (or rule of law) in Canadian jurisprudence that provides that the nature of a debtor's trade debt or of a debtor's gain from the forgiveness of a trade debt changes automatically merely because of the passage of time in a taxation year or a number of taxation years. … British Mexican has been distinguished in a number of subsequent Canadian decisions, including Alco Dispensing … [indicating that] the release of the liability to pay the bonuses could not be treated as having changed the character of the liability, … [and] it was contrary to common sense … to assert that the passage of a year end effects some sort of a magical conversion of executive compensation operations from current account transactions to capital account transactions. ...