Search - 报销 发票日期 消费日期不一致

By virtue of subsection 56.1(1) … the recipient is deemed to have received the support payments that were made to the child of the age of majority … [and] subsection 60.1(1) deems the amounts, paid by the payer to the child of the age of majority, to be paid to the recipient. Thus, to the extent that the amounts paid by the payer represent "support" amounts … the amounts are both deductible by the payer and taxable to the recipient. ...

By virtue of subsection 56.1(1) … the recipient is deemed to have received the support payments that were made to the child of the age of majority … [and] subsection 60.1(1) deems the amounts, paid by the payer to the child of the age of majority, to be paid to the recipient. Thus, to the extent that the amounts paid by the payer represent "support" amounts … the amounts are both deductible by the payer and taxable to the recipient. ...

CRA stated: Under clause 53(2)(c)(i)(B) … the ACB of an interest in a partnership must be reduced by … farm losses without regard to section 31. … The ACB of the taxpayer's interest would therefore be reduced by $75,000 even though the taxpayer has an unused restricted farm loss of $57,500. ...

Regarding the transfer of the RESP to the testamentary trust, CRA stated: [A] subscriber … includes each individual, other than a trust (the "original subscriber") who has subscribed to the plan with the promoter and, after the death of that individual, any other person (including the estate of the original subscriber) who acquires the individual's rights as a subscriber to the plan …. …[I]f a trust acquires rights from the original subscriber after the original subscriber’s death as a subscriber to the plan, or if a testamentary trust makes contributions to the RESP after the death of the original subscriber, that trust will be a subscriber …. ...

See, for example … Diktakis …. As such, half-siblings would qualify as being connected by a blood relationship since they are individuals who have a common parent …. ...

6 April 2003 External T.I. 2003-0054461E5 F- Traitement fiscal d'un cadeau-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income “gift” may be business income to the recipient In indicating that an amount described as a “gift” could be business income to the recipient, CRA stated: …IT-334R2[, para. 4] … states that voluntary payments received by virtue of a profession or by virtue of carrying on a business are taxable receipts. Paragraph 11 … states that if the hobby or pastime results in receipts of revenue in excess of expenses, that fact is a strong indication that the hobby is a venture with an expectation of profit. In such case, the net income may be taxable as business income. … [P]articipation in a specific arrangement that allows for the receipt of money may be an indicator that the money is business income and therefore taxable. ...

CRA stated: … Articles 1119 and following [of the Civil Code] provide for the modes of dismemberment of the right of ownership. Usufruct or right of use seem to be the types of dismemberment of ownership that could apply …. [T]he application of subsection 248(3) to the transfer would have the effect of deeming Monsieur and Madam to have disposed of the entire immovable (the property and income rights in the immovable) to a trust. … The election under subsection 85(1) would not be valid since the transfer would not be made to the corporation but rather to the trust. ...

Accordingly … a LIRA is simply an RRSP and a LIF is a RRIF. … [A]mounts received from a LIF, i.e., a RRIF, do not constitute a life annuity out of or under a pension plan. Consequently, such income is not qualified pension income and does not qualify for the pension credit …. ...

Subsection 69(11) would therefore not apply to increase the individuals' proceeds of disposition …. [W]here there is no transaction to circumvent the application of subsection 69(11) … subsection 245(2) would not apply, since the series of transactions would result in the utilization of the losses by a person affiliated with those who benefited from the tax-deferred transfer, and this would not constitute an abuse of the Act read as a whole …. ...

However … consideration should continue to be given to legal form with respect to items that are required to be included in the computation of capital either as loans, advances or indebtedness. Consequently … the amount of a government grant that is presented by way of note to the financial statements as a reduction of capital property is not "any other surplus" … [and] will not be included in capital pursuant to paragraph 181.2(3)(a). ...