Search - 报销 发票日期 消费日期不一致

In finding that the Allowance might in fact be a reimbursement, in which case, it likely would be non-taxable, CRA stated: [E]ven if the employer uses the term "allowance" to refer to the payment made to an employee, it is possible that … the allowance may be a reimbursement of expenses. Consequently, if … the Allowance is, for example, based on an estimate of the travel and accommodation costs that the Employee will incur during the training period, or that Mr. A must show the Employer how the Allowance was spent, then it may be that the Allowance is more of an expense reimbursement and not a taxable allowance pursuant to paragraph 6(1)(b). … [G]iven that … the training appears to be primarily for the benefit of the Employer, the $15,500 Allowance may be non-taxable to Mr. ...

CRA stated: The guarantee … is provided by the Fund solely to enable Holdco to access the financial markets by issuing a short form prospectus in order to benefit from the expediency and other advantages stemming from that procedure. ... [P]rovided that all the conditions of section 253.1 … are met and that the Fund is not engaged in the business of lending money or guaranteeing loans …the requirements of subsection 132(6) … are not violated by the mere fact that the Fund provides the guarantee …. ...

CRA stated: Where, in a taxation year of an estate, the estate receives [such] an amount … and subsequently transfers it to its beneficiaries, the estate must include the amount received and may deduct the amount transferred in computing its income for that taxation year pursuant to paragraphs 56(1)(a) and 104(6)(b) of the Act, respectively. In this case, there would be no tax consequences to the estate, but rather to the beneficiaries who must include the amount transferred from the estate in their income pursuant to paragraph 104(13)(a). … Since [the estate] 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). ...

Regarding the resulting disposition, the Directorate stated: In the case of property forfeited by statute … the definitions of "disposition" and "proceeds of disposition" … are broad enough to include the disposition of the property at the time it is forfeited, for proceeds of disposition that are nil…. ... [Here] there was a disposition of the seized equipment … at the time the court confiscated the property pursuant to section 16 of the Controlled Drugs and Substances Act. … [T]ax treatment of such equipment dispositions should be in accordance with the Act regardless of whether they are derived from illegal activity. ...

(e)(iii) exclusion applied, CRA stated: [T]he wording of the exclusion … allow[s], inter alia, an employee's own vehicle that is used in the course of employment under the conditions set out in that subparagraph, and for which the employee's expenses are not reimbursed by the employee's employer, to be excluded from the definition of automobile …. [T]he exception in subparagraph (e)(iii) … may even apply to a self-employed person who primarily uses the individual’s vehicle at a location described in subparagraphs 6(6)(a)(i) or (ii) …. ...

. … The amount of sales taxes paid by the charity need not be considered … nor should the amount of tips be considered. … [I]f the value of the free items given to all participants in the golf tournament, for each ticket sold, does not exceed the lesser of $75 and 10% of the ticket price, this amount will not be considered an advantage …. ...

CRA responded: … $1,000 … would be a function of the FMV of the net assets of Bco. Since Bco would have no liabilities at that time, it appears to us that the total FMV of Bco's assets would also be $1,000 immediately before the particular time. … [A] method of determining the FMV of property of a particular prescribed class based on objective data such as an independent appraisal report, a price list, a sales transaction of similar property, etc., would generally be an acceptable method. … [I]n this case the amounts established by the independent appraiser could be used as a basis for allocating the $1,000 to the various assets of Bco immediately prior to the time of the acquisition of control. ...

. … Desjardins J.A. of the Federal Court of Appeal stated that the former wording of subsection 248(3) allowed the concepts of beneficial ownership (possession, use and risk) to be applied to the leasing contracts at issue. In our view, this interpretation is contrary to Parliament's intention, which was to consider certain civil law situations equivalent to beneficial ownership in order to remedy certain problems created by the non-existence of that concept in Quebec civil law. … [T]he Federal Court of Appeal emphasized the importance of applying the Act uniformly across Canada, regardless of the legal system. The Court therefore concluded that the position in … IT-233R, as it existed at the time … applied to all taxpayers at that time. ...

., 1996 J.Q. no. 5103 … established that support and custody judgments lose all effect when the parents resume living together … [and] that these judgments would not take effect if the parents subsequently separated again. … Since the amounts were paid under a new agreement, which was only a verbal agreement between the parties, that arose following the second separation, the amounts paid by Monsieur do not meet the definition of "support amount" in subsection 56.1(4) …. ...

CCRA indicated that s. 110.6(15)(a) would apply, stating: In the context of paragraph 110.6(15)(a) … the term "owned" refers to the person who beneficially owns the property. … Opco owns a life insurance policy on the life of Ms. ... Consequently … the shares of Opco owned by the Trust are deemed to be beneficially owned by Ms. A for the purposes of the Act …. ...