Search - 江西农大 毛瑢

The Queen, [[1987] 1 C.T.C. 265] [[87 C.T.C. 265 (FCTD), Dube, 3 stated "... ...

Paragraph 18(1)(m) of the Act provides that no deduction shall be made in respect of "... any amount... paid or payable by virtue of an obligation imposed by statute to (i) Her Majesty in right of... a province, (ii) an agent of Her Majesty in right of... a province, or (iii) a corporation, commission or association that is controlled by Her Majesty in right of.. a province or by an agent of Her Majesty in right of.. a province as a royalty, tax..., lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or (v) the production in Canada of... ...

They have the following characteristics: Cost equal to paid-up capital ("PUC") $ 1 Adjusted cost base ("ACB") equal to valuation day amount $1,000,000 Redemption value and fair market value, immediately before Father's death $3,000,000 Those shares were received on the freeze of Father's interest in an operating company. 3. ...

In that year, you have concluded he would report the following income for tax purposes: Interest Income Original Issue Discount 51.48 less Interest Included in A's incom per sub- section 20(14) (20.60) Interest included in B's income 30.88 Capital Gains Total Proceeds Received 100.00 less Proceeds on account of Interest (51.48) Proceeds on Account of Principal Amont 48.52 Cost (price paid less price on account of interest) (56.45- 20.60 = 35.85) (35.85) Capital gain (loss) 12.67 Taxable Capital Gain 6.34 We confirm that the coupon interest of the Bond would be treated according to the usual rules while the original issue discount would be treated in the manner described in the foregoing example. ...

Department of National Revenue response (a) Subject to certain readjustments provided for therein, (b) paragraph 89(1)(c) of the Act provides that the "paid-up capital" in respect of a share of any class of the capital stock of a corporation constitutes "... an amount equal to the paid-up capital in respect of that class of shares at that time, computed without reference to the provisions of this Act... ...

DAMAN Chief Finance, Insurance, & Leasing Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...

Cette disposition s'applique pour les dispositions de biens survenues après le 15 février 1984. 2 & 3. ...

Second sentence, typographical error in the spelling of the word " circumstance". 2. ...

Vance Sider Chief Foreign & Small Business Section Revenue Canada, Taxation 3rd Floor 88 Metcalfe Street Ottawa, Ontario KlA 0L8 Dear Mr. ...

& 3. L'alinéa 12(1)b) de la Loi stipule que toute somme recevable par un contribuable au titre de la vente de biens ou de la fourniture de services au cours de l'année, dans le cadre de l'exploitation de son entreprise, doit être incluse dans le calcul de son revenu tiré d'une entreprise. ...