Search - 报销 发票日期 消费日期不一致

The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...

. … [T]he only significance of the fact that the penalty is assessable in respect of Year X and not Year X+7 is… the de minimis rule in paragraph 247(3)(b)…. ...

However, recognizing an upstream loan would result in double counting because the assets acquired by the parent out of the proceeds thereof would already be counted for purposes of the tests – so that the loan’s value decreases the relevant FMV of the shares of the particular wholly-owned subsidiary. ...

The Directorate confirmed the TSO approach, which was to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...

14 January 2010 Internal T.I. 2009-0323991I7 F- Débenture échangeable et opération à terme-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) only ½ deduction under s. 20(1)(f)(ii) for premium paid on cash-settling an exchangeable debenture under pre-2010 policy, and no s. 20(1)(f) deduction for cash settlement of forward A predecessor of the taxpayer had issued an exchangeable debenture exchangeable into share of a corporation (“Corporation 2”) of which the taxpayer was one of the shareholders. ...

To the extent that these entities are related … subsection 96(2.2)(c) would not be applicable for the purpose of reducing Canco's at-risk amount to the extent that the various borrowings have a legitimate business purpose and are not related to the acquisition of Canco's interest in USLP. ...

After noting that, in light of s. 249.1(3), this entailed a request for an amendment retroactive to the end of the previous fiscal year ending February 27, 2007, the Directorate stated: In general, a request for a change of fiscal year will be approved if it can be shown that the request is motivated solely by valid business reasons ….. ...

. … Since the PAFU is primarily intended to meet the needs of people affected by an emergency situation, we believe that the financial assistance that will be paid by the MESS in the form of a lump sum to cover living expenses and/or specific costs will be paid after a review of needs by the MESS, without the MESS conducting a means or income test for people affected by an emergency situation. ...

Consequently, there is no provision in provincial legislation affecting Part IA corporations … for the power of the majority shareholder to control the election of the board of directors to be limited or altered by means of a USA. ...

The fact that the franchisor does not itself deliver the goods does not invalidate the application of subparagraph 20(1)(m)(i) … ...