Search - 水晶光电 行业地位 发展趋势

28 April 2004 Internal T.I. 2004-0067561I7 F- Impôt de la partie I.3-- summary under Paragraph 87(2)(a) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) no IT-474, para. 10 relief for acceleration of Part I.3 tax In connection with the taxpayer’s reference to the statement in IT-474, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences which are unfavourable to the taxpayer, the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate,” the Directorate indicated that no such relief was available respecting an acceleration of Part I.3 tax resulting from an amalgamation. ...

The Directorate noted: For the purposes of the definition of "commencement day", the child support amount is considered to have been changed if the amount of child support paid is changed … regardless of the number of children covered by that support. ...

The Directorate stated: [T]he tax payable under subsection (e) of section 1159.2 … is a payroll tax that may be deducted in computing the taxpayer's income. ...

25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) amount paid by corporation on conversion of convertible debentures was the stated capital of the issued shares, being the debentures’ face amount, so that no s. 20(1)(f) deduction The issuer, whose convertible debentures were converted, sought to take a ¾ deduction under s. 20(1)(f) based on the excess of the market value of the shares into which the debentures were converted over the face amount of the debentures. ...

16 August 2002 Internal T.I. 2002-0156577 F- ASSURANCE- INVALIDITE- PARITE-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) previous contributions could be deducted from subsequent equalization adjustment received In finding that a taxpayer could deduct contributions made to a disability insurance plan between 1990 and 2001 from an equalization adjustment received in 2001 that related to disability insurance benefits received by the taxpayer in 1988, the Directorate stated: [T]he wording of the Act does not restrict the deductibility of contributions made between 1990 and 2001, even though they were made after the first benefits were paid in 1988 …. ...

Therefore, the pension benefit will be deemed to be income of the beneficiary for the year from a property that is an interest in the Estate and not from any other source pursuant to subsection 108(5) ….. ...

9 March 2000 Internal T.I. 2000-0008257 F- Mandat d'inaptitude-- summary under Paragraph 256(1.4)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) s. 256(1.4) generally applies to a power of attorney In determining whether two corporations are associated, a mandatary under a power of attorney would be deemed under s. 256(1.4) to be the owner of the shares of a corporation held by the grantor, if the powers of the mandatary include the power to control the voting rights attached to the shares owned by the principal – except that s. 256(1.4)(a) provides an exception if the right to control the voting rights cannot be exercised because its exercise is contingent on the death, bankruptcy or permanent disability of an individual. ...

4 July 2025 Internal T.I. 2025-1054791I7 F- Provincial allocation- CEWS-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) gross revenue does not include government assistance re expenses CRA indicated that the Canadian emergency wage subsidy ("CEWS") should be excluded in computing gross revenue for the purposes of the interprovincial income allocation formula in Reg. 402(3) in accordance with CRA’s “longstanding position … that financial assistance received by a corporation from a government in respect of expenditures incurred or to be incurred by the taxpayer is normally excluded in determining gross revenue” for Reg. 402(3) purposes. ...

However, in its immediately preceding taxation year, the definition of "investment business" in subsection 95(1) … did not apply to FA2 with reference to Canco because that definition only applies with reference to a "a foreign affiliate of a taxpayer". ... After noting that the wording of s. 138(11.91)(e) "does not mesh well with the definition of ECE" in s. 14(5) given that such definition requires an "outlay or expense made or incurred … as a result of a transaction," CRA nonetheless concluded that the wording of s. 138(11.91)(e) of the Act was "sufficient to cause FA2 to be considered to have made an ECE at the relevant time. ...

. … Consequently, there is no provision in provincial legislation affecting Part IA corporations under the QCA for the power of shareholders to control the election of the board of directors to be limited or modified by way of a USA. ... Furthermore …it should be noted that the number of votes required to elect the directors of the Corporation has not changed even though each group of shareholders has one designate. … In addition, corporations controlled by X that hold the voting shares cannot appoint a majority of the directors and there is nothing in the documents you sent to us to indicate that the person designated by Trust is a person designated by X. ...