Search - 报销 发票日期 消费日期不一致

In general, the courts have preferred to tax sources that are enumerated and/or provided for under a specific provision of the Act (see Schwartz … and Fries …). ...

2 October 2001 External T.I. 2001-0102655 F- T5008- AGENT DE L'ACHETEUR-- summary under Subsection 230(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 230- Subsection 230(6) purchase made as agent does require filing a T5008 In connection with finding that a trust company acting as agent for a purchaser of stock-exchange shares pursuant to a public offering need not file a T5008 slip pursuant to Reg. 230(2) or (6), CCRA stated: [Reg.] 230(6) … would not apply to a person who acts as an agent or nominee to effect a purchase for a person who is not a trader or dealer in securities as defined in [Reg.] 230(1) …. ...

. … [T]herefore … a corporation that pays certain of its directors remuneration consisting solely of shares of the corporation would not be required to deduct source deductions on the value of this remuneration in shares. ...

As the term “individual” … exclude[s] a corporation, the registered charity … would not qualify as an RESP subscriber. ...

. … [T]he payment of a dividend by a particular payer can only affect that payer’s entitlement to a subsidy under subsection 125.7(2) of the Act as a result of the application of subsection 125.7(2.01) …. ...

28 February 2001 External T.I. 2000-0016765 F- All or substantially all-- summary under Clause 110.6(14)(f)(ii)(A) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(ii)- Clause 110.6(14)(f)(ii)(A) all or substantially all test in s. 110.6(14)(f)(ii)(A) is generally but not always a 90% of FMV test Regarding the meaning of the expressions “all or substantially all the assets used in an active business” in ss. 110.6(14)(f)(ii)(A) and 54.2, CCRA stated: FMV is generally the best measure for calculating “all or substantially all of the assets” of a business for the purposes of those provisions …. However … other units of measurement could apply since those provisions of the Act do not state any particular unit of measurement that must be used. ...

No director, member, or officer shall directly or indirectly receive any profit from his / her position as director, member, or officer. However, it is permitted that a director or officer may be reimbursed for reasonable expenses incurred by him / her in the performance of his / her duties. ... The objects of the corporation must be to only carry on and / or promote SR&ED. ...

. $6,000- [6000/(6,000 + 6,000) x $2,000]). The total U.S. tax paid in the year was $6080 (i.e. the taxable income for U.S. tax purposes of $16,000 multiplied by the U.S. tax rate of 38%) The portion of such amount that is applicable to the capital gain computed pursuant to Canadian tax law is in our view $2,316 (i.e. the proportion of the U.S. tax that the capital gain for Canadian tax purposes is of the U.S. taxable income before the application of the U.S. loss carry-forwards). … The portion of the $2,316 that would need to be considered reasonably applicable to the 1991 FAPI TCG in order to eliminate Canadian tax in respect thereof would be $1,900 as this amount multiplied by the relevant tax factor for the purposes of paragraph 91(4)(a) produces a deduction equal to the 1991 FAPI TCG ($5,000). A further deduction in respect of U.S. tax paid on the balance of the capital gain reported for U.S. tax purposes may be available under subsection 91(4) of the Act if the original disposition of the property gave rise to an income inclusion under subsection 91(1) of the Act in the 5 immediately preceding years. … The amount included in computing Canco's income in 1991 by virtue of subsection 91(1) of the Act in respect of the passive interest earned by FA after the deduction of the relevant portion of the deductible loss is $5,000 (i.e.$6,000-[6,000/(6,000 + 6,000) x $2,000]). ...

CRA stated: Provided there is clear evidence, at the time of the disposition of the excluded property, that arrangements are being made for the repayment (with due dispatch) of the "related debt"...the fact that the actual repayment of the debt occurs after the disposition of the excluded property would not, in and by itself, result in the debt not being considered "... related at all times... ". However if it was determined that other factors (such as cash flow problems, or unfavourable prevailing interest or exchange rates) contributed to the delay in repayment, it is likely that the provisions of paragraph 95(2)(i) would not apply on the repayment of the debt. ...

26 September 2013 External T.I. 2013-0497101E5 F- Avantage imposable consenti par un actionnaire-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) gift made by shareholder-manager to corporate employee “not received … on a purely personal basis” Is a gift received by an employee of a corporation from a shareholder manager, that would have been taxable under s. 6(1)(a) had it been provided by the corporation, taxable to the employee? In responding affirmatively, CRA stated: In order for a gift or benefit received by an employee to come within paragraph 6(1)(a), it is sufficient if there is some connection between the gift received and an office or employment of the taxpayer and that the gift was not received by the employee on a purely personal basis. … [E]verything indicates that the employee received the gift because of the employment held with the corporation. ...