Search - 水晶光电 行业地位 发展趋势

24 November 2013 CTF Roundtable, 2013-0508151C6- Upstream Loans-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt repayment by set-off A loan or indebtedness will be considered to have been repaid by a debtor by way of set-off against a receivable of the debtor "if the set-off represents a legal discharge of the loan or indebtedness. ...

19 November 2012 External T.I. 2012-0459351E5- Shale Gas Well Drilling Classification-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development In considering the conditions under which a shale gas well would qualify for Canadian development expense credits, CRA noted that drilling the well may qualify for scientific research and experimental development credits if done for "experimental development of a new technology. ...

10 June 2011 Roundtable, 2011-0404621C6 F- Rectification order in Québec-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission CRA awaiting resolution of AES and Riopel cases CRA noted that as the ARQ had sought leave to appeal the AES decision to the Supreme Court and the period for seeking leave in Riopel had not yet expired, it would prefer to refrain from commenting on those decisions effect on CRA’s views on rectification. ...

25 March 2009 External T.I. 2008-0300401E5 F- Fiducie en faveur de soi-même- prêt sans intérêt-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt individual pays trust taxes when he receives trust distributions net of such taxes CRA indicated that an individual would be considered to be personally paying taxes of a trust that had made a s. 104(13.1) where he received distributions from the trust net of such taxes. ...

6 July 1994 Administrative Letter 9323826 F- Bonds Issued in Lieu of Interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of bonds re accrued interest did not constitute payment thereof Bonds issued to a Canadian bank in settlement of arrears interest on a non-performing loan of a Brazilian debtor would not be considered to constitute payment by the debtor and receipt by the bank of interest on the underlying loans, in light of the comments in Cross v. ...

5 January 1996 CTF Roundtable Q. 31, 9523976- GROSS-UP PAYMENTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where the gross-up is paid or credited to the government of a foreign country on the Canadian lender's behalf since the Canadian lender would have constructively received the gross-up". ...

29 April 2003 External T.I. 2002-0177065 F- CONFISCATION DE LA SOLDE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received CCRA indicated that salary that was forfeited by RCMP officer for misconduct nonetheless was to be treated as includible in the officer’s income as salary which was to be treated as having been received by the individual before its forfeiture as a fine. ...

25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital CCRA reviewed the line of cases culminating in Teleglobe, and concluded that the amount paid by the issuer on the conversion of its convertible debentures should be treated as the stated capital of the shares issued, which equaled the face amount of the converted debentures. ...

2021 Ruling 2021-0911211R3- Foreign Takeover-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt borrowing and payment of funds pursuant to an internal payment direction agreement CRA ruled on transactions which included the borrowing of money by a newly-formed non-resident corporation (Merger Sub1) from a Canadian affiliate (Opco) and its advance of such funds to a transfer agent for shareholders of a non-resident target (Target), pursuant to directions in an internal funding agreement. ...

10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F- 2014 APFF Roundtable, Q. 15- Section 143.4 & Reverse Earn-out-- summary under Subsection 143.4(2) Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(2) reverse earnout obligation of Buyco re Target shares A newly formed corporation ("Newco") purchases the shares of a target corporation ("Target") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven). ... However we can offer the following general comments which nonetheless, in some circumstances, would not apply in a particular situation. … … (a) …[A] reduction in the cost of the shares in the capital stock of Target through the application of subsection 143.4(2) prior to the amalgamation would in general permit the debt to qualify as "excluded obligation" as defined in subsection 80(1), by reason of the application of paragraph (a) of that definition. ...