Search - 报销 发票日期 消费日期不一致

In finding that s. 248(3)(e) would deem the Opco shares to be owned by the spouse for s. 110.6(15)(a) purposes, CCRA stated: 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 …. ...

CCRA responded: … Firm B, cannot carry on mutual fund sales activities because this firm is not registered in group savings but only in life and health insurance. ... X as stated in Income Tax Technical News No. 22. … Mr. X cannot represent Firm A without being remunerated for the services he renders to that firm. ... X must be assessed in a manner that is reasonable in the circumstances. … … [A]n amount of commissions received by Firm A could be allocated to Firm B as compensation for services rendered by Firm B to Firm A such as, for example, the use of Firm B's client network. ...

"[T]he CCRA does not generally presume that non-arm's length relationships exist in transactions involving uncles and nephews … [although] family ties may be more likely to give rise to the existence of a non-arm's length relationship between particular persons." "[I]f … the brothers' children were to become shareholders of Opco by having their corporation systematically acquire shares from one of their uncles, instead of shares belonging to their own father, this would … have a significant impact on the question of determining whether the Purchaser and the Vendor are not dealing at arm's length with each other …." ...

. … [I]f the employee did not intend at the time the salary deferral arrangement was created to return to work after the leave for a period at least equal to the duration of the leave, the deferred amounts must be included in the employee's income in the taxation year in which they were deferred. … In addition, if the employee decides during the course of the arrangement to retire at the end of the leave and does not return to work as initially provided for in the arrangement, the deferred amounts will be taxed in the year in which it is known that the above-described condition will not be satisfied. ... The Directorate responded: [I]f, prior to the leave, an employee was working full-time, then upon the employee’s return to work, the employee must once again work full-time within the employer's business …. If the employee was working part-time before the leave, the employee may return to work part-time or on a busier schedule …. ...

. … Folio S1-F1-C1 … states that, notwithstanding several exceptions, “eligible medical expenses are not restricted to those paid in Canada or for medical services provided in Canada”. Whether ‘all or substantially all’ of the premiums paid under the … plan relate to medical expenses that are eligible for the …METC … is a question of fact and can only be determined by the insurer of the plan. ...

B could not … benefit from the rollover … because as consideration for the disposition of the shares they held in the predecessor corporations, they received, in addition to the shares of the capital stock of Amalco, consideration other than shares due to the amalgamation. … Subparagraph (b)(iii) of the definition of "disposition" in subsection 248(1) provides that a disposition of any property includes any transaction or event by which a share is converted because of an amalgamation or merger. ... B would therefore be deemed to have disposed of their shares in the capital stock of the predecessor corporations at the fair market value of such shares …. ...

. … [P]aragraph [146.1(6.1)(b)] could cause the years of existence of the transferring RESP to be taken into account in determining when "accumulated income payments" may be made under the receiving RESP pursuant to 146.1(2)(d.1). If applicable, those years would also be taken into account in determining the maximum duration of the receiving RESP provided in paragraph 146.1(2)(i) and determining the period during which contributions may be made into the receiving RESP pursuant to paragraph 146.1(2)(h). … However, depending on the circumstances, a transfer between RESPs could result in the subscriber of the transferring RESP, the receiving RESP, or both, having to pay tax under subsection 204.91(1) … [but not in] the situation described …. ...

. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account …. ... [If] … the expenditure brings into existence an asset or advantage that has an enduring benefit... it is denied current deduction …. ...

. … [I]n the event of the death of one of the joint tenants, the property will belong solely to the surviving joint tenant. Whether two … joint tenants … of a share in a MIC should be counted as one shareholder or two individual shareholders for purposes of paragraph 130.1(6)(d) of the Act is a mixed question of fact and law …. ...

CRA responded: [F]or [s. 164(6)] to apply, the legal representative must dispose of the capital property of the estate or all of the depreciable property of a prescribed class … within the first taxation year of the estate. … Furthermore …[t]he COVID-19 Time Limits Act temporarily enables the Minister responsible for the application of a federal Act … to suspend or extend certain time limits … for a maximum of six months, by order. ...