Search - 水晶光电 行业地位 发展趋势
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Technical Interpretation - Internal summary
25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE -- summary under Payment & Receipt
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. ...
Technical Interpretation - Internal summary
27 March 2018 Internal T.I. 2017-0691941I7 F - Investissement frauduleux – Fraudulent Investment -- summary under Subparagraph 20(1)(p)(i)
27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) Ponzi scheme investors can generally write off their reinvested interest income in the year the perpetrators are charged Individuals had “invested” in what turned out to be a Ponzi scheme under which for many years they paid income taxes on interest reported as being earned by them, with such interest being reinvested. ... The Directorate indicated that because various of the taxation years were before the 10-year period, they could not be so reassessed – and, in any event, the interest had been required to be recognized in the years in which the individuals received or were entitled to receive it. The Directorate went on to indicate that potential relief could be provided though a subsequent bad debt deduction – likely, in the year in which the promoters were charged. ...
Technical Interpretation - Internal summary
2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits -- summary under Payment & Receipt
2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 Although CRA usually applies its constructive receipt concepts in the context of employment income recognition, it has applied that concept to pension income recognition under s. 56(1)(a)(i). ... Its reasoning was that the amount could not be considered to be “received” as a pension benefit in the year of payment by the RPP administrator to the Directorate because the right-holder had not yet been identified – whereas in the subsequent year of payment over by the Directorate to the right-holder, that right-holder is receiving that amount under s. 56(1)(a)(i) as being “in lieu of” a superannuation or pension benefit. ...
Technical Interpretation - Internal summary
16 March 2015 Internal T.I. 2013-0479861I7 - Section 116 & forfeited deposits on real property -- summary under Paragraph (b)
16 March 2015 Internal T.I. 2013-0479861I7- Section 116 & forfeited deposits on real property-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (b) forfeited sale deposit was proceeds Before finding that a deposit forfeited to a non-resident vendor under an agreement for sale of B.C. real property (due to failure of the purchaser to close) did not represent proceeds of taxable Canadian property by virtue of s. 248(4), CRA first stated (based on the s. 248(1) – "disposition" definition) that "there is a disposition of a right under a contract where an agreement of sale has been cancelled and the buyer's deposit is forfeited to the vendor," ...
Technical Interpretation - Internal summary
30 June 1995 Internal T.I. 9503907 - TAX STATUS OF CHEQUE RETURNED BY CASH METHOD FARMER? -- summary under Payment & Receipt
-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt of cheque (that is not subsequently dishonoured) is payment at that time A payment by cheque is equivalent to a payment in cash as long as no special circumstances lead to another conclusion, and the cheque is not dishonoured on presentation for payment. ...
Technical Interpretation - Internal summary
29 March 2021 Internal T.I. 2020-0865791I7 - CEWS - eligible remuneration -- summary under Payment & Receipt
29 March 2021 Internal T.I. 2020-0865791I7- CEWS- eligible remuneration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt remuneration not considered to be paid by journal entry The CEWS (wage subsidy) is generated based on the amounts of “eligible remuneration paid to the eligible employee.” ...
Technical Interpretation - Internal summary
6 March 2015 Internal T.I. 2014-0549761I7 - Internally generated goodwill & excluded property -- summary under Subsection 149(10)
6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) unpurchased goodwill is taken into account Before going on to indicate that internally generated goodwill is considered in determining whether shares of a foreign affiliate of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate of the corporation, CRA noted that in 9319777 and in 2002-0126653 "this Directorate took the position that internally generated goodwill was property of the taxpayer immediately prior to the transition time such that it was deemed to be disposed of, and reacquired, by the taxpayer for an amount equal to its fair market value." See summary under s. 95(1) – excluded property. ...
Technical Interpretation - Internal summary
6 March 2015 Internal T.I. 2014-0549761I7 - Internally generated goodwill & excluded property -- summary under Small Business Corporation
6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation unpurchased goodwill is taken into account Before going on to indicate that internally generated goodwill is considered in determining whether shares of a foreign affiliate of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate of the corporation, CRA stated: [T]he "all or substantially all" test will normally be satisfied if assets representing at least 90 percent of the fair market value of the assets of the corporation are used in an active business carried on by it. ... See summary under s. 95(1) – excluded property. ...
Technical Interpretation - Internal summary
22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution -- summary under Subsection 248(5)
22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 248(5) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt dividends to Canco) to another wholly-owned subsidiary (Luxco1). ...
Technical Interpretation - Internal summary
16 January 2017 Internal T.I. 2016-0651411I7 - Reassessment period – transfer pricing -- summary under Subparagraph 402(3)(a)(i)
16 January 2017 Internal T.I. 2016-0651411I7- Reassessment period – transfer pricing-- summary under Subparagraph 402(3)(a)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3)- Paragraph 402(3)(a)- Subparagraph 402(3)(a)(i) reallocation of gross revenue consequential on s. 247(2) assessment A s. 247(2) transfer-pricing adjustment (“TPA”) was reassessed by CRA within the three years after the normal reassessment period to increase the sales proceeds on a cross-border sale. ... The Directorate found that CRA was also authorized by s. 152(4)(b)(iii) to reassess so as to reallocate both the pre-TPA and additional TPA revenue among the provinces – apparently even though this might only affect relative provincial taxable income and not affect federal taxable income (given that the TPA reassessment had already occurred). ...