Search - 报销 发票日期 消费日期不一致

CRA responded: [P]aragraph 107(4.1)(c) … provides an exception to the application of subsection 107(4.1) if the property (or a property for which it was substituted) that was distributed had been originally transferred to the trust by the capital beneficiary or by that beneficiary’s spouse or common-law partner (being, in the latter case, an individual to whom subsection 73(1) applies). … [S]ubsection 107(4.1) applies to the distribution of the commercial rental property by the trust to its sole beneficiary. ...

14 June 2012 External T.I. 2012-0443711E5 F- RAP- Annulation de la vente de l'immeuble-- summary under Eligible Amount Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Eligible Amount subsequent court-ordered voiding of home purchase funded with HBP does not affect satisfaction of the HBP conditions In confirming that a judgment declaring a sale of a home to be void would not affect the operation of the HBP rules where the home in question was acquired under an HBP, CRA stated: Eligibility for withdrawing funds from an RRSP under the HBP … is not affected by the occurrence of subsequent events. As a result, once all the conditions to participate in the HBP are met and a withdrawal has been made from an RRSP, it is not possible to cancel participation in the HBP. … In addition, subject to special repayment situations, the repayment period for withdrawals under this HBP remains unchanged by the voiding of the sale. ...

However, [such] passage of time … may be one of the factors to be considered in determining whether the conditions set out in the definition of death benefit in subsection 248(1) are otherwise satisfied …. ...

. … The allocation method adopted must generally be established in a reasonable and appropriate manner depending on the taxpayer's business location. It must also be applied consistently by the taxpayer for as long as it carries on its business. … ...

However, once the CRA has informed the taxpayer that it will be reviewing the income or the tax payable of the taxpayer under the VDP … the professional fees incurred by the taxpayer from that time onward in support of the taxpayer’s position are deductible under paragraph 60(o) …. ...

Trailer rental also includes various services such as utilities, snow removal, grounds maintenance, supply and washing of bedding, supply of cleaning products and other maintenance – and also provides housekeeping services two to three times a week for each trailer. After assuming that the rented trailers were real property, CRA stated: [T]he extent to which basic services and additional services are provided to tenants... will determine whether the activity generates income from a business. … [W]e believe that the income generated by the trailer rental corporation is active business income. ...

In commenting on the meaning of “incurred,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

13 March 2012 External T.I. 2012-0433661E5 F- Notion de dépense engagée-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense expense not incurred if obligation therefor dependent on future contingency Before noting that “the concepts of ‘outlay or expense incurred’ under paragraph 18(1)(a) can apply to expenses incurred for the purposes of the medical expense tax credit,” CRA stated: … Wawang … stated: [T]he correct question to ask, in determining whether a legal obligation is contingent at a particular point in time, is whether the legal obligation has come into existence at that time, or whether no obligation will come into existence until the occurrence of an event that may not occur. ...

CRA stated: [A]ny amount paid to a retiree by Taxpayerco should be included in computing the retiree’s income under either section 5 or section 6 … [as] the payment … arises necessarily from the retiree’s employment with Taxpayerco. ...

In finding that the royalties were exempt under s. 212(1)(d)(vi), CRA stated: 9730076 and 2003-0018975 … no longer represent the position of the CRA. The practice of the CRA is to the effect that a royalty or similar payment respecting a copyright is not subject to any withholding tax under Part XIII …. ...