Search - 报销 发票日期 消费日期不一致

Respecting the accessing of a further carve-out (which applies inter alia where the property that is disposed of to unrelated persons as part of the series constitutes less than 10% of the FMV of all of the butterflied property- ignoring for these purposes, money and indebtedness), the property so disposed of cannot exceed 10% of the total value of the butterflied property at any time after the butterfly and prior to the end of the series – so that even if the FMV of certain property constituted, for example, 7% of the total FMV on the disposition date, it might exceed 10% of the total FMV at some point between the butterfly date and the disposition date, so as to put the butterfly offside. ...

However, CRA indicated that if Opco reimbursed the Holdcos for the premiums, it would become a question of fact as to whether s. 246(1) applies (even in the absence of the s. 246(2) exception) and that such reimbursements potentially could be included in their incomes pursuant to s. 9 or 12(1)(x) – but regardless of whether there was such an inclusion, the premiums would be non-deductible to the Holdcos because “premiums paid under a life insurance policy are not deductible in computing a taxpayer's business income because they are capital expenditures.” ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

29 December 2022- 11:08pm The proposed version of s. 85.1(4) is overly broad Email this Content The current version of s. 85.1(4) avoids deferral of the capital gain that would otherwise be realized on the outright sale of a directly held FA (the first affiliate) through transferring it under s. 85.1(3) to a second affiliate, which then sells the first affiliate shares to a subsequent acquiror – where the first affiliate shares are excluded property so that such sale occurs on a deferred basis. ...

Summary of 2021 Ruling 2020-0852541R3 F under s. 55(1) – distribution. ...

The scholarship exemption for an award received by a PT “qualifying student” is generally limited to the cost of materials related to the program, the fees paid to the “designated educational institution” (DEI) in respect of the program, and the basic scholarship exemption of $500 – whereas the full amount of the grant received by an FT qualifying student is eligible for the scholarship exemption under s. 56(3)(a) provided (in the words of CRA) “it is reasonable to conclude that the award is intended to support the individual’s enrolment in the program.” ...

Summary of 2021 Ruling 2020-0862431R3 F under s. 248(1) – disposition. ...

The test in s. 144.1(2)(e)(i)(A) requires that the “trust … contains at least one class of beneficiaries where the members of the class represent at least 25% of all of the beneficiaries of the trust who are employees of the participating employers under the trust.” ...

., generally, it was for occupancy as a place of residence of the lessee for over one month) or 6.1 (where there was an exempt sublease), the portions of the upfront payments that were “attributable” to such lease intervals would be exempted – whereas the portion of the upfront payment attributable to any subsequent lease intervals where the use became taxable would be subject to GST/HST. ...

Summary of 2021 Ruling 2021-0904311R3 F under s. 55(1) – distribution. ...