Search - 枣庄市市中区 智博公考 地址 电话

Assuming that an amount under the guarantee agreement became payable within 12 months after the time of the cessation of Aco’s business, s. 39(12) applied to all amounts repaid under the guarantee agreement – so that Mr. ...

. … Opco Before the [above] transfers of shares…Opco was controlled by a related group…consist[ing] of either A and B, or Holdco A and Holdco B. ...

. … Our conclusion would be the same if the transactions respecting a freeze of Opco in order to introduce Nephew were part of the series of transactions that included the deemed dividend received by Holdco as a result of the redemption of the Class "D" shares of the capital stock of Opco held by Holdco, as Nephew and Nephew Inc. were related to Holdco, the dividend recipient, by virtue of subparagraphs 251(2)(b)(iii) and 251(2)(c)(ii), respectively. ...

. … If it is established on the facts that the taxpayer ordinarily occupied Residences 1, 2, and 3, the move from Residence 1 to Residence 2 is considered a relocation, and that from Residence 2 to Residence 3 as a second relocation. ...

…[W]e refer you to… 2002-0147325 …. 2 nd Situation. Same as 1 st situation except that, rather than subscribing for preferred shares of Holdco, Opco declares a dividend on its common shares (held by Mr. ...

A could under subsection 20(12) opt to claim, in his 2014 Canadian income tax return, an amount of up to $400…[which] would reduce the amount of his “non-business income tax” for 2014 …. ...

CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...

In this type of arrangement (or one where the employee only receives advances during the leave – in which case, it is not within the DSLP rules), the employee is entitled to a s. 8(1)(n) deduction as the advances are “repaid” (i.e., out of reduced pay cheques following the return to work). ...

. … [Respecting] the last condition…provided that at the time FA Finco receives the amount of penalty, FA Holdco continues to hold the shares of FA Opco that constitute a source of income for FA Holdco, the fourth condition of Clause D would be satisfied. ...

. … …[T]his type of deduction would not be covered by any of the exceptions set out in the definition of "annuities" in Article 18, paragraph 5….. ...