Search - 江西农大 毛瑢

18 March 2014 External T.I. 2013-0511191E5- Taxable Benefits – Weight Management Programs CRA Tags 6(1)(a) 6(1)(a)(iv) Principal Issues: Whether an employer-subsidized weight management program is a taxable employment benefit? ... Baltkois March 18, 2014 Dear XXXXXXXXXX: Re: Taxable benefits – weight management program We are writing in response to your correspondence dated November 1, 2013, wherein you requested our comments concerning whether a weight management program subsidized by an employer as part of an overall wellness initiative would result in a taxable benefit to participating employees. ...

25 September 2012 CTF Roundtable Q. 4, 2012-0457581C6- CTF BC – Q4 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate British Columbia Tax Conference September 25, 2012 Question 4 – Residency of a Trust for Tax Purposes CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c) CRA Tags 93.2 Principal Issues: Whether paragraph 95(2)(c) applies in a situation where a taxpayer transfers shares of a foreign affiliate to another foreign affiliate that is a “non-resident corporation without share capital”, within the meaning of subsection 93.2(1), without any “shares” being issued as consideration? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 10 – Interaction of section 93.2 and paragraph 95(2)(c) It is our understanding that subsection 93.2(3) was introduced with the specific purpose of facilitating the application of paragraph 95(2)(c), among other provisions, to “non-resident corporations without share capital”, within the meaning of subsection 93.2(1). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election CRA Tags 108(1) Principal Issues: 1. ... STEP CRA Roundtable – June 10, 2016 Question 4. Qualified Disability Trust and Preferred Beneficiary Election There are a number of conditions that must be met in order for a trust to be eligible to be a Qualified Disability Trust (“QDT”) for a particular tax year. ...

26 May 2016 External T.I. 2016-0627441E5- Employment expenses – long-haul truck driver Unedited CRA Tags 8(2), 8(1)(g), 8(1)(h), 8(1)(h.1), 8(1)(i)(iii), 8(1)(j), 8(4), 8(10), 67.1(1), 67.1(5), 67.1(1.1), 230(1), 248(1) Principal Issues: Deductibility of expenses by a long-haul truck driver. ... Underhill May 26, 2016 Dear XXXXXXXXXX: Re: Employment expenses – long-haul truck driver We are writing in response to your letter dated December 29, 2015, concerning what expenses a long-haul truck driver may deduct from his or her employment income. ...

7 January 2009 Internal T.I. 2008-0304901I7- Taxation & Insolvency Unedited CRA Tags 164(1) Principal Issues: Whether all post-bankruptcy refunds vest automatically in a trustee in bankruptcy. ... Diegel & Feick Inc. (1980), 35 C.B.R. (N.S.) 309 (Ont. S.C.); Re Sihler (1982), 43 C.B.R. ...

5 November 1998 External T.I. 9818445- JOINT TENANTS & TENANTS IN COMMON Unedited CRA Tags 70(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons: The provision of subsection 70(5) will deemed the interest in the property to be disposed of at fair market value under both tenancy arrangements. 5-981844 XXXXXXXXXX Karen Power, CA (613) 957-8953 November 5, 1998 Dear XXXXXXXXXX: Re: Joint Tenancy & Tenants in Common We are writing in reply to your letter of June 8, 1998, concerning the taxation of property owned by yourself and your brother and sister. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business Unedited CRA Tags 120.4 Principal Issues: Whether dividend income earned by a spouse who works as a part-time receptionist in the business would be subject to TOSI. ... Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 4. ...

1 August 2019 External T.I. 2018-0768561E5- Application Administrative Position on US LLPs & LLLP Unedited CRA Tags 248(1) "corporation" Principal Issues: Further to the CRA's administrative position that a LLP or LLLP formed before April 26, 2017 that would otherwise be viewed as a corporation by the CRA may in certain circumstances continue to be viewed as a partnership, what are the Canadian tax implications of the LLLP described in this letter subsequently taking the position that it is a corporation for Canadian tax purposes? ... Moreno August 1, 2019 Dear XXXXXXXXXX: Re: Administrative Position on US LLPs & LLLPs This is in reply to your letter of June 29, 2018. ...

8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6- Insurance Proceeds & CDA Unedited CRA Tags "capital dividend account" defn in ss. 89(1); s. 148; ss. 248(1), Reg. 306, Reg.1401(3) Principal Issues: Whether the "fund value" portion of a payment made under an exempt single-life life insurance policy by an insurer to a corporation as a consequence of the death of the life insured under the policy is "proceeds of life insurance" for purposes of subparagraph (d)(ii) of the definition of capital dividend account in subsection 89(1). ... The scheme of these rules generally provide for the taxation of amounts received by a policyholder out of the policy prior to the death of the life insured under the policy, but on a tax-free basis where they are paid out as a consequence of the death of the life insured. 2020 CALU CRA Roundtable – July 2020 Question 3- Proceeds of an Insurance Policy and Calculation of the CDA credit Background One of the death benefit patterns permitted under a Universal Life (UL) policy is often referred to as “face amount plus fund value”. ...