Search - 江苏苏美达轻纺国际贸易有限公司 关税政策 最新动态

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

Situation (b) The same as Situation (a) except that a holding company (HC), resident in a non-treaty country, was interposed for non-tax reasons between Foreign MNC and FE – but with the funding for the acquisition of the Canco shares still having come from Foreign MNC, and with any dividends paid flowing up to Foreign MNC. ...

A variant of this situation was the same except that a holding company (HC), resident in a non-treaty country, was interposed for non-tax reasons between Foreign MNC and FE – but with the funding for the acquisition of the Canco shares still having come from Foreign MNC. ...

CRA indicated that since Canco and Holdco each held the USco shares directly for a portion of their 2023 taxation year, each would be a reporting entity that was required to file a T1134 for their 2023 taxation year – however, as a related group with the same year end, and using the same functional currency, they could designate one of them as their representative to file a single T1134 information return with the required information for both. ...

X's daughter purchased the shares from a person with whom she was dealing at arm's length … the ACB of those shares should not be reduced by paragraph 84.1(2)(a.1), for the purposes of section 84.1. ...

8 October 2010 Roundtable, 2010-0373191C6 F- Computation of safe income-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) where interest in partnership holding Subco with safe income is rolled into Holdco for prefs, dividends from Subco do not change consolidated SIOH of prefs – or increase commons’ SIOH The partnership interest (in “SENC,” which holds all the shares of Subco, to which safe income is attributable) of an individual (X) was transferred under s. 85(1) at its adjusted cost base rather than its higher FMV to an unrelated holding corporation ("Holdco") in consideration for Class B preferred shares of Holdco. ...

C in each year and making an s. 104(22) designation so that the income retains its character as U.S. source income in his hands – or could he elect under s. 94(16) so that the trust’s income will be attributed to him? ...

. … In order to be eligible for a joint designation, amounts must be distributed from the FHSA to the estate before the deceased holder's FHSA ceases to be a FHSA, generally before the end of the year following the year of the holder's death, unless the FHSA ceased to be a FHSA at an earlier date under subsection 146.6(16). ...