Search - 江西农大 毛瑢

STEP CRA ROUNDTABLE – June 2012 Question 5: There can be an issue when an estate elects under subsection 164(6) to apply a capital loss to the terminal return of the deceased. ...

IFA Roundtable, May 2014 Question 5 Question 5: ACB of Shares of FAs – Relief for Internal Reorganization When a partnership in which a Canadian corporation (Canco) is a member receives a pre-acquisition surplus dividend from a foreign affiliate (FA), there is no immediate reduction to the ACB of the shares of the FA. ...

Reasons: Legislation 2011 STEP Conference June 2-3, 2011 QUESTION #14 – VOLUNTARY DISCLOSURE We understand that because the Fairness Provisions can be exercised only for a ten-year period following amendment to subsection 220(3.1), CRA in handling Voluntary Disclosures may be precluded from waiving penalties which arise in respect of matters more than ten years old. ...

Ontario CTF Conference – October 30, 2012 Question 15 Part 1 In IC00-1R2, at paragraph 11, the CRA states that a taxpayer who makes a valid voluntary disclosure will not be assessed any penalties or prosecuted. ...

MAY 23, 2013 CRA ROUND TABLE 2013 IFA INTERNATIONAL TAX SEMINAR Question 9 – Convertible and Exchangeable Debentures What is the CRA's current position with respect to the application of the Part XIII tax to convertible and exchangeable debentures owned by foreign lenders (i.e., paragraph 212(1)(b), the definition of "participating debt interest" in subsection 212(3), subsection 214(7) and their qualification as an "excluded obligation" under paragraph 214(8)(c) of the ITA)? ...

However, we are currently considering whether Article XXI of Canada-Singapore Income Tax Convention provides implicit authority to override the time limitation in subsection 227(6). 2011 Canadian Tax Foundation Conference November 27-29, 2011 Canada Revenue Agency Round Table – Question 4 Article XXI of the Canada-Singapore Income Tax Convention (1977) (the "Singapore Treaty") limits the extent to which Canada is obligated to provide treaty benefits in respect of Canadian-source income derived by a resident of Singapore. ...

However, any US tax paid in respect of a corporation's share of the income of an LLC would be paid by the corporation in respect of income from a share of the capital stock of a foreign affiliate of the corporation. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 6. ...

., a 20% shareholder or member is tax-exempt or otherwise not subject to income taxation in the foreign jurisdiction on the relevant income. 2015 Canadian Tax Foundation Conference CRA Roundtable Question 9 – Sub-subclause 95(2)(a)(ii)(D)(IV)(2): Fiscally Transparent Entities One of the exceptions from treating interest income earned by a foreign affiliate of a Canadian taxpayer as FAPI is found in clause 95(2)(a)(ii)(D) of the ITA. ...

Reasons: The wording of the relevant provisions of the Act and our previous interpretations. 2016 International Fiscal Association Conference CRA Roundtable Question 11- PLOIs – Multiple amounts receivable and late-filing penalties A corporation resident in Canada (“CRIC”) sold products and/or provided services to customers both within and outside Canada. ...

Position: Yes Reasons: To the extent that a Canadian ULC is disregarded for U.S. tax purposes, the interest income paid by the ULC would not receive the “same treatment” as it would have received if the ULC was treated as being a regarded entity for U.S. tax purposes and as such, subparagraph 7(b) of Article IV of the Treaty would apply to deny Treaty benefits to the US S Corporation parent in respect of that interest income. 2016 International Fiscal Association Conference CRA Roundtable Question 9 – Application of Subparagraph 7(b) of Article IV to S-corporations Assume the following hypothetical facts: a) US Parent, a U.S. ...