Search - 枣庄市市中区 智博公考 地址 电话

(b) Here, in contrast, the fact that the trustee may make payments over the three years suggests that the trustee may have discretion and the payments may be voluntary – so that the payments to the charity over the three years may be eligible for the donation tax credit. ...

Reg. 204 imposes a requirement to file a T3 return where the trustee has control of, or receives, income, gains, or profits in the trustee’s fiduciary capacity – even if the Trust computes nil income. ...

After responding negatively, CRA stated:... 2009-0347491C6 … provided examples of acceptable notifications of the payment of an eligible dividend from a corporation other than a public corporation to the dividend recipient. ...

The taxpayer will therefore have to file two worksheets and two T2091 forms … if the taxpayer wishes to designate Unit 2 and Unit 3 as his principal residence for the applicable years. ...

Should the safe income attributable to the shares of Holdco be reduced by negative safe income given that the latter does not reduce the accrued capital gain in the shares – or is such amount $900,000? ...

. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...

CRA indicated that the loss carryback requested on the form T3A filed with the 2 nd return will not be processed concurrently with the T3 return for 1 st taxation year, as the loss must first be recognized by CRA before it can be applied to the earlier taxation year – so that the initial notice of assessment for the 1 st taxation year would not reflect the carryback, and would show interest owing where the computed balance of tax owing was not paid on or before March 31. ...

In addition …, it would be appropriate to consider that the same conclusion would apply regardless of whether or not the transactions are being undertaken to avoid the 21-year deemed disposition rule in subsection 104(4). ...

Here, as the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares – so that the value of the common shares would not take the policy CSV into account. ...

(g)(ii) (where the beneficiary is 24 years before the particular year), CRA stated: In a situation where the individual has not assumed any risk, whether an arm’s length rate of interest charged is a reasonable return is a mixed question of fact and law …. ...