Search - 江西农大 毛瑢

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician Principal Issues: Question 7 of the 2019 Step Conference. 1. ... Reasons: Our previous position. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 7. ...

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA Unedited CRA Tags 89(1) "capital dividend account", 148(9) "disposition" Principal Issues: Whether or not a payment under a particular life insurance policy would be considered proceeds of a life insurance policy in consequence of death for purposes of the definition of “capital dividend account” in subsection 89(1) of the Act. ... Reasons: The determination is a question of fact. 2020 CALU CRA Roundtable – July 2020 Question 2- Return of premiums on death- Capital Dividend Account Background With respect to the calculation of a corporation’s capital dividend account, when proceeds of a life insurance policy are received by the corporation, paragraph (d) of the definition of “capital dividend account” in subsection 89(1) of the Act provides for, in part, the inclusion of the following [subject to reductions listed in subparagraphs (d)(iii) to (d)(vi) of that definition] “all amounts each of which is the proceeds of a life insurance policy… of which the corporation was… a beneficiary… received by the corporation… in consequence of the death of any person” [emphasis added] The term “proceeds of a life insurance policy” is not defined in the Act. ...

8 September 2021 External T.I. 2021-0879941E5- METC – Cost of a nebulizer Unedited CRA Tags ITA: subsections 118.2(2); 118.4(2); subparagraph 118.2(2)(m), and IT Regulation 5700. ... Underhill September 8, 2021 Dear XXXXXXXXXX: Re: Medical expenses – Nebulizer We are writing in response to your correspondence received on February 4, 2021, asking if the cost of a home nebulizer, including a replacement part such as a nebulizer cup, is an eligible medical expense for the purposes of the medical expense tax credit (METC). ...

28 January 2022 External T.I. 2020-0860211E5- Principal Residence Exemption – Unedited CRA Tags Paragraph 54(e)- definition of principal residence and land in excess of one-half hectare; 40(2)(b) Principal Issues: Whether the taxpayers are eligible to claim the principal residence exemption on the portion of their land in excess of one-half hectare. ... Foggia, CPA, CA January 28, 2022 Dear XXXXXXXXXX: Re: Principal Residence Exemption – Excess Land This is in response to your correspondence of August 4, 2020 and a subsequent telephone conversation (Couvrette/XXXXXXXXXX) of August 25, 2020, wherein you requested our views concerning the disposition of a residence where the total area of the land upon which the housing unit is situated exceeds one-half hectare. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries Unedited CRA Tags 144.1(2)(e) and (f) Principal Issues: Whether a group comprised of employees from multiple participating employers who are entitled to different benefit entitlements may constitute a class of beneficiaries for purposes of subparagraph 144.1(2)(e)(i) of the Act. ... Zabolotney December 5, 2022 Dear XXXXXXXXXX: Re: Employee Life and Health Trusts – Class of beneficiaries We are writing in reply to your correspondence of November 3, 2021, wherein you asked for our comments regarding the beneficiary class rules in paragraph 144.1(2)(e) of the Income Tax Act (the ”Act”). ...

7 May 2024 CALU Roundtable Q. 4, 2024-1007061C6- Shared Ownership & Charitable Gift Unedited CRA Tags 118.1, 148, 248 Principal Issues: Can the CRA provide an update on its views with respect to shared-ownership arrangements in the context of charitable giving? ... CALU Roundtable- May 2024 Question 4 – Shared Ownership Arrangements and Charitable Gifting Background There are circumstances where two parties may wish to jointly own and benefit from a life insurance policy. ...

4 June 2024 STEP Roundtable Q. 10, 2024-1010241C6- Update on trust / estate issues Unedited CRA Tags 104(6)(b); 104(13); 104(24) and 105(1) Principal Issues: Can CRA provide an update on any recent trust or estate issues that may be of interest to the STEP audience? ... Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 10. ...

10 May 2004 Internal T.I. 2004-0057511I7- NRH&WTrust:Barbados, Bermuda & Cayman Islands Unedited CRA Tags 75(3) Principal Issues: Does 75(3) apply to Non-Resident Health and Welfare Trusts located in specific jurisdictions? ... May 10, 2004 International Tax Directorate Pascal Tétrault 344 Slater Street, 6th Floor Ottawa, Ontario Attention: Linda Smith 2004-005751 Operation of 75(3) & Non-Resident Health and Welfare Trusts We are writing in response to your email of January 20, 2004 regarding the above captioned matter. ... It is also relevant to reproduce paragraph (a.1) of the definition "trust" in subsection 108(1), which reads: 108. (1) Definitions- In this subdivision, "trust" includes an inter vivos trust and a testamentary trust but in subsections 104(4), (5), (5.2), (12), (13.1), (13.2), (14) and (15) and sections 105 to 107 does not include [...] ...

31 July 2019 External T.I. 2019-0798361E5- Business use of vehicles – maintenance employees Unedited CRA Tags 6(1)(a) Principal Issues: Whether maintenance employees travel would be considered personal in various circumstances. ... XXXXXXXXXX 2019-079836 Sarah Springate July 31, 2019 Dear XXXXXXXXXX: Re: Business use of vehicles – maintenance employees We are writing in response to your correspondence of February 27, 2019 and our (Springate/XXXXXXXXXX) subsequent telephone conversation of June 3, 2019, in which you requested clarification as to whether the travel of certain maintenance employees in employer provided motor vehicles (the Vehicles) would be considered personal in certain circumstances. ... For further information on keeping records, please refer to Chapter 2 – Automobile and motor vehicle benefits and allowances of the CRA’s Guide T4130, Employers’ Guide Taxable Benefits and Allowances. ...

4 March 2015 External T.I. 2014-0537941E5- Non-Profit Organization – fibre-optic cable CRA Tags 149(1)(l) Principal Issues: Whether the income generated from the fibre-optic cable network would jeopardize the not-for-profit status of the Institute. ... XXXXXXXXXX 2014-053794 Ananthy Mahendran (905) 721-5204 March 4, 2015 Dear XXXXXXXXXX: Re: Non-Profit Organization – Revenue from the Fibre-Optic Cable Network This is in response to your email of June 20, 2014, requesting our comments on the application of paragraph 149(1)(l) of the Income Tax Act (the "Act") to XXXXXXXXXX ("the Institute"). ...