Search - 枣庄市市中区 智博公考 地址 电话

Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ...

Since the equitable interest of the donee arose at the moment of the creation of the trust, CRA did not construe there to be a gift of substituted property by the GRE – so that s. 118.1(5.1)(b) did not apply. ...

22 June 2020 External T.I. 2020-0848721E5 F- SSUC- Entité déterminée et institution publique-- summary under Subsection 149(1.1) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1.1) example of application of s. 149(1.1) In the course of a general response to a query by a non-profit organization regarding the exclusion from an "eligible entity" for CEWS purposes of a “public institution” as defined in s, 125.7 (including an organization described in any of ss. 149(1)(a) to (d.6),) CRA stated: [S[subsection 149(1.1) … provides that for the purposes of determining the 100% and 90% ownership tests in paragraphs 149(1)(d) to (d.6) of the Act any right to acquire shares or capital of a corporation should be considered as though the right had been exercised. ...

Consequently, the client would not qualify for the wage subsidy in respect of the payment made to the staffing company … [Y]ou mentioned that the client has received an offsetting discount for the wage subsidy received by the outsource staffing company. ...

. … Although a leasing agreement is often referred to as a financing agreement, the CRA believes that the leasing agreement cannot be considered a true loan. ...

However a textual, contextual and purposive interpretation of subparagraph 55(5)(e)(i) does not allow us to override its wording …. ...

(e) that the required certification be “completed … no more than 12 months before the time that the agreement is made,” CRA stated: This wording suggests that the Certification is to be completed before the time the flow-through share agreement is made (but not more than 12 months before that time), although it doesn’t expressly mandate that the Certification be completed before the flow-through share agreement is made (rather than after). ...

. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...

More specifically, paragraph (c) of the definition of AAII … deals with adjustments to the definition of "income" or "loss" as defined in subsection 129(4) and does not provide for any adjustment related to the Deemed ABI which is defined under paragraph 129(6)(b). ...

In responding, “yes,” CRA stated: [T]he fact that premiums and contributions paid by an employer are not made directly to a trust will also not, in and of itself, impair that trusts’ ability to qualify as an ELHT, as there is no requirement in section 144.1 … which explicitly requires that an employer make contributions directly to an ELHT (or to any extent whatsoever). ...