Search - 报销 发票日期 消费日期不一致

Summary of 13 March 2020 External T.I. 2019-0833181E5 under s. 120.4(1)- excluded share – (a)(i). ...

Summaries of 24 June 2020 External T.I. 2018-0747781E5 under s. 248(1) – superannuation or pension benefit and s. 60(j). ...

24 September 2020- 9:18am CRA indicates that there is no requirement to distribute income on a TFSA overcontribution where there has been 1% monthly tax but no advantage tax Email this Content CRA confirmed that the only adverse consequence of a TFSA over-contribution is the 1% monthly tax under s. 207.02 on the highest “excess TFSA amount” for each month (subject to such penalty tax being waived under s. 207.06(1)) – unless there is a “deliberate over-contribution,” which CRA indicated referred “to a TFSA contribution knowingly made by an individual in excess of their TFSA contribution limit, generally with a view to generating a rate of return sufficient to outweigh the cost of the 1% tax.” ...

Summaries of 11 August 2020 Internal T.I. 2018-0782181I7 under s. 66.7(3) and s. 18(1)(a) – incurring of expense. ...

When asked whether this position also applies to a trust that is an alter ego trust or a joint spousal trust or a common-law partner trust, CRA noted that in order to meet the conditions of s. 73(1.01)(c), the alter ego trust must be a trust under which no person except the settlor may receive or otherwise obtain the use of any of the income or capital of the trust before the settlor’s death – and similarly, for a joint spousal trust or a common-law spousal trust. ...

Since the benefit … arises from the issuance of shares, paragraph 7(3)(b) precludes a deduction by EmployerCo in respect of that benefit. ...

26 November 2020- 10:57am CRA finds that the purchase and rental of furniture in a furnished apartment is assimilated to the apartment rental activity Email this Content S. 149(1)(o.2)(ii)(A)(II) permits a s. 149(1)(o.2) (pension-group) corporation to invest its funds in “a partnership that limits its activities to acquiring, holding, maintaining, improving, leasing or managing capital property that is real property or an interest in real property … owned by the partnership”. ...

., the deemed $80,000 proceeds of disposition of the capital interest under s. 107(2)(c), being the excess of the $100,000 cost amount of the distributed property, being their deemed cost to the beneficiary, over the $20,000 eligible offset amount) – whereas, for capital loss purposes, the ACB of the capital loss was determined as nil on ordinary principles, so that there also was no loss. ...

Summary of 26 November 2020 STEP Roundtable, Q.9 under s. 120.4(1) – excluded business. ...

CRA ruled that “[t]he negative repo spread … will not be considered to be interest or an amount paid or credited as, on account or in lieu of, or in satisfaction of interest for the purposes of paragraph 212(1)(b).” ...