Search - 报销 发票日期 消费日期不一致

. … [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. ...

CRA responded: [A]n individual owned a home that he inhabited during the four-year period referred to in subparagraph (a)(ii) … if he owned the home he inhabited during that period as his principal place of residence. … [A]n individual does not meet the condition set out in subparagraph (a)(ii) … if the individual owned a home, located in Canada or outside Canada, that he inhabited as his principal place of residence in the four-year period referred to in subparagraph (a)(ii) …. ...

. … [A] housing unit in a semi-commercial building would also be a "qualifying home" …. ... The term "principal place of residence" is not defined …. ...

26 June 2001 External T.I. 2001-0068285 F- DATE DE DISPOSITION ACTIONS EN BOURSE-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (a) disposition date on a stock exchange is the settlement date, being the due date for the proceeds In finding that a taxpayer may not uses the trade date rather than the settlement date as the date of disposition of publicly traded shares, CCRA stated: A "disposition", as defined … [to] include … "any transaction or event entitling a taxpayer to proceeds of disposition of the property". Consequently … there is no disposition before the vendor is entitled to the proceeds of disposition, i.e. on the settlement date. ...

CRA stated: PARENT would … not be eligible for a deduction under subsection 91(5) … with respect to the dividend received from CFA2, given that the ACB of the CFA2 shares for PARENT was not subject to any adjustment under paragraph 92(1)(a) …. ...

. … This is so since, for the purposes of the Act, income reallocated under subsection 75(2) does not constitute income realized by the trust, paid or payable to Mr. X. … In the event that subsection 75(2) is inapplicable … it would generally be possible to make an election under subsection 104(13.1) to tax income earned in a taxation year in the Trust. … First, an election under subsection 104(13.1) could be made where the income for the year would be distributed to Mr. ... X could be made [by] …: reimbursement of the trustee by Mr. X, payment by cheques by Mr. ...

CRA responded: Paragraph … 95(2)(f.11) would not have any impact on the computation of FA1’s FAPI/FAPL. ... Further … clause 95(2)(a)(ii)(D) would not apply to the interest paid or payable by FA1 to the Bank. Therefore, if FA1 does not have any other amounts to be included in the computation of FAPI, the interest deduction for the interest paid or payable to the Bank would result in a FAPL in respect of FA1. … Canco is not required to deduct the interest expense paid or payable by FA1 to the Bank when computing FAPI of FA1, since paragraph 20(1)(c) is a discretionary deduction …. ...

B's death …. The cost to Mr. A of the Residence could … include the portion, if any, of the legal fees and payment to Ms. B that was incurred in connection with the acquisition of the Residence. … It is … possible that, through [the] transfer contract, Mr. ... This portion of the costs … could [not] be added to or capitalized to the cost of the Residence. ...

This means that the deemed inclusion of the fair market value of the fund property will be in the hands of the second-to-die of the two spouses – except to the extent that there then is a transfer out of the fund to a financially dependent child or other eligible beneficiary (in which case, the eligible amount of the transfer is included in the transferee’s income under s. 146.3(5)(a). In particular after defining the surviving spouse of the annuitant or a financially dependent child or grandchild (as defined in the s. 146(1) – “refund of premiums” definition) as an “Eligible Recipient,” and describing the two types of “designated benefits” in s. 146.3(1), CRA stated (TaxInterpretations translation): the amount that is included in computing the deceased’s income, under subsection 146.3(5) and paragraph 56(1)(t), will be equal to the FMV of the RRIF property upon the death of the annuitant minus the amount determined under subsection 146.3(6.2). However, the amount of this reduction will be a benefit to be included in computing the income of the Eligible Recipient. … In summary, subsection 146.3(6.2) allows for the determination of what portion of the designated benefit will be included in computing the deceased annuitant's income and what portion will be included in computing the income of the Eligible Recipient. ...