Search - 报销 发票日期 消费日期不一致

Summary of 2022 Ruling 2021-0884331R3 under s. 55(1) – distribution and s. 86(1). ...

The authors suggest: [I]t is far from certain that tax attributes can be successfully eliminated through the new proposals unless it is impossible to articulate a credible non-abusive future use of those attributes …. ...

20 September 2022- 11:30pm CRA explains the ETA s. 213.2 rules for importing goods free of GST Email this Content CRA described ETA s. 213.2 as establishing an import certificate regime allowing registered importers to obtain a CRA certificate permitting them to import- free of GST/HST otherwise imposed at the border – goods owned by a non-resident person for the purpose of providing a storage or distribution service, or performing certain manufacturing or processing services, in respect of those goods prior to their export (with the provision also extending to the importation of goods or raw materials, other than fuels, lubricants and plant equipment, for consumption or absorption directly in the processing of other goods for export.) ...

Summary of 18 July 2022 External T.I. 2021-0887121E5 under s. 248(1) – inventory. ...

(e) of the “flow-through critical mineral mining expenditure” definition that the required certification by a “qualified engineer or geoscientist” be “completed … no more than 12 months before the time that the agreement is made”: This wording suggests that the Certification is to be completed before the time the flow-through share agreement is made (but not more than 12 months before that time), although it doesn’t expressly mandate that the Certification be completed before the flow-through share agreement is made (rather than after). ...

S. 118.1(16) provided that the gift amounts were to be reduced by a loan made back to the corporation by the charity within the following 60 months – so that, for example, the 2007 gift amount could be reduced by the 2012 loanback amount. ...

CRA maintained its “longstanding position that to the extent that contingencies and accounting reserves have the effect of reducing the inherent gain on a corporation's share, such amounts should reduce the corporation's safe income on hand” – but indicated that it would “be prepared to consider more specific situations in the context of a request for advance rulings….” ...

After noting that, under s. 40(1)(a)(ii), the availability of the reserve turned on Brother-Portfolioco and Brother not having de facto control of Sister-Holdco and on Sister-Holdco not having de facto control of Brother-Portfolioco, CRA commented on the expansion of de facto control under s. 256(5.11) stating: As provided for in subsection 256(5.11) and the applicable jurisprudence, any factor, whether contractual, commercial, economic, moral or familial, may be taken into consideration in order to determine whether a person or group of persons has influence, direct or indirect, the exercise of which would result in de facto control of a corporation …. ...

CRA indicated that, no, its position remained that premiums payable in respect of a CII policy assigned as security for a loan of the corporation cannot be deducted in computing its income from a business or property since they are capital expenditures, and are not deductible pursuant to s. 20(1)(e), (e.1) or (e.2) – and that this position would not change if the CII policy was assigned to the lender by naming the lender as the beneficiary of the policy. ...

Summary of 7 October 2022 APFF Financial Strategies and Instruments Roundtable, Q.7 under s. 146.01(1) – regular eligible amount- para. ...