Search - 江苏苏美达轻纺国际贸易有限公司 关税政策 最新动态

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

. … [I]t is our view that the First Parking Space is a component of the housing unit (i.e., the Condo). ...

CCRA stated: [T]he Agency's position … is that a corporation that redeems shares held by one of its shareholders may pay its entire capital dividend account to that shareholder, provided that subsection 83(2.1) does not apply. ...

. … Expenses paid to a “private health services plan” as a premium, contribution or other consideration in respect of, among others, the individual or the individual's spouse generally qualify as medical expenses under paragraph 118.2(2)(q) except to the extent that the payment was deducted by the individual as a business expense under subsection 20.01(1). ...

. … [F]or an individual disability insurance policy to be a component of a group insurance plan, it must be determined whether the level of benefits and the ratio of contributions to the plan shared by the employer and the employee are similar to those of the other employees covered by the same plan. ...

After noting that there would be no taxable benefit under s. 6(1)(a) from the employer's payment of the premiums if this arrangement qualified as a group plan described in s. 6(1)(a)(i), CRA went on to note that its general presumption “that an employee shareholder receives benefits or allowances in their capacity as a shareholder if they can significantly influence the policies of the corporation” can be rebutted if “all employees of the corporation are entitled to the benefit” or if all employees are shareholders or related to a shareholder and the benefit “is comparable (in nature and amount) to the benefits … generally offered by corporations of the same size to non-shareholder employees whose services and responsibilities are similar.” ...

Consequently, in the example … a trust created for a minor child under the will would be considered a “testamentary trust” under the definition in subsection 108(1), assuming that paragraphs (a), (b) and (c) of that definition do not apply. ...

On December 31, 2016, Opco had accumulated $100,000 in after-tax profits and safe income, As there were 200 outstanding AA and X shares, the X class shares had a redemption value on January 1, 2017 of $50,100 (($100,000 x 100/200) + $100 of PUC) On January 1, 2017, Opco paid a dividend of $50,000 to Holdco. ... After noting the Robertson rule that “income will be attributable to a particular class of shares in the same ratio in which each class would be entitled if all earnings of the corporation, but not share capital, were to be distributed,” CRA stated: [G]iven that…the Class X and AA shares were entitled to an equal share of Opco’s profits following the issuance of the Class X shares and that the value of the shares of each class would increase due to this share of profits, … the safe income earned or realized annually following the issuance of the Class X Shares could be proportionately allocated based on the number of shares of each class. ...

However, after taking into account [Reg.] 5900(3) …, since in computing the income of CFA1 and CFA2 FP is treated as if it were a separate person resident in Canada, subsection 91(5) of the Act would apply to permit a deduction by FP of the Foreign Dividends received by FP with the result that, with respect to such Foreign Dividends, there is no net income from property that would be included in the value of "A" in the definition of FAPI with respect to CFA1 and CFA2. ...