Search - 江西农大 毛瑢
Results 351 - 360 of 79192 for 江西农大 毛瑢
GST/HST Ruling
16 November 2017 GST/HST Ruling 183644 - – […] child care services
The Corporation, […], provides weekly summer day camps […][in July and August]. 9. ... The Corporation, […], provides an after-school program during the school year. 13. ... A supply of services made under the […] after-school program is exempt from GST/HST. ...
GST/HST Interpretation
6 June 2014 GST/HST Interpretation 150533 - Application of Section 162 to Forestry […] Management Agreements […]
You wrote in response to an interpretation issued to your firm by the […] Region of the Canada Revenue Agency (CRA) on [mm/dd/yyyy], case number […]. ... Section […] of the agreement provides that A Co will carry out Services and Harvesting Activities to achieve the results specified in the Forestry Documents. […]. ... Paragraph […] of the agreement and paragraph […] to the agreement provide that B Co will pay for harvested timber that is accepted by B Co. ...
Conference
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6 - Curr Use & 95(2)(a)(ii)(B) & (D)
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D) Unedited CRA Tags Clauses 95(2)(a)(ii)(B) and (D), paragraph 20(1)(c), subsection 5907(1) of the Income Tax Regulations Principal Issues: How the current use approach would apply in analyzing clauses 95(2)(a)(ii)(B) and (D) to two specific examples. ...
FCA (summary)
Canadian Forest Navigation Co. Ltd. v. Canada, 2017 FCA 39 -- summary under Rectification & Rescission
Canada, 2017 FCA 39-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission foreign rectification order not dispositive The taxpayer’s Barbados and Cyprus subsidiaries paid amounts to the taxpayer in 2004, 2005 and 2006 as dividends and then, following CRA proposals to assess the dividends, obtained rectification orders from the applicable Barbados and Cyprus courts declaring that the amounts instead were loans to it (or otherwise gave rise to indebtedness). ... Moreover, since these foreign orders involve the appellant and its Foreign Affiliates and not the Minister, a third-party to the foreign proceedings, there is nothing to enforce against the Minister; homologation is therefore a non-issue. … However, Boivin JA further stated (at paras 19-20): I cannot agree … that pursuant to article 2822 C.c.Q. these foreign orders are dispositive and that the Minister has no choice under the ITA but to accept the dividends are actually loans because the orders from Barbados and Cyprus say so. ... These determinations are for the Tax Court judge to make, with a full evidentiary record at his or her disposal. … On this basis, he concluded that Lamarre ACJ should not have answered the Rule 58 question, and set aside her judgment and dismissed the Rule 58 motion before the Tax Court. ...
News of Note post
3 September 2019- 11:53pm Yellow Point – Tax Court of Canada finds that an ecological gift was made in the year before it was certified as such Email this Content A taxpayer, who donated an interest in ecologically sensitive land to two qualified donees in 2008, unsuccessfully argued that the gift was not made until 2009 for purposes of computing the five-year (now 10-year) carryforward period described in s. 110.1(1)(d)(iii), because it was not until 2009 that he received certification from the Minister of the Environment as to the lands’ ecologically sensitive nature. Visser, J stated: [A] gift has been made … when a donor legally effects a voluntary transfer of property to a donee …. … [T]he certificates are necessary to claim a deduction under paragraph 110.1(1)(d) … but not to determine if a gift of land has been “made” for the purpose of paragraph 110.1(1)(d). ...
News of Note post
Bocock J found: Non est factum is available where a person is not capable of both reading and sufficiently understanding a document. … … Anna from and after her diagnosis date, lacked mental capacity to execute or did not execute and file the 2003 filings…. Therefore, the notices of reassessments responsive to the 2003 filings … were void. … [T]he reassessments were consequential to invalid or unlawful filings and issued by the Minister under innocent mistake of fact. Accordingly, no objection was required to the void reassessments. … Bocock J went on to vacate those reassessments. ...
News of Note post
14 February 2022- 11:01pm Lussier – Court of Quebec finds no taxable benefit in an insurance company employee attending a conference for insurance brokers in Cancun Email this Content The taxpayer, was designated by his employer (“BMO,” an insurance company) to attend a one-week conference for insurance brokers and financial advisors whom one of BMO’s managing general agents had identified as top “performers.” ... In reversing the ARQ assessment to include 62.5% of the cost of the trip in the taxpayer’s income as a taxable benefit, Pilon JCQ stated: The recreational activities were an opportunity to create or maintain relationships with advisors and brokers. … … [T]he ARQ's … approach is somewhat penalizing and unfair to Mr. ... His employer did not give him the choice to participate in a trip, on which he went alone, and where he was expected to work and develop business, which he did, both during business hours and beyond. … [T]he ARQ's position stems either from a misunderstanding of what constitutes the steps required for business development where there is a legitimate growth objective, or from a desire to dictate to a business what its business model should be and how to achieve it. ...
Technical Interpretation - Internal summary
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1) -- summary under Paragraph 85(1)(e.2)
15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Paragraph 85(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e.2) significant FMV shortfall suggested that a benefit was desired to be conferred Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... In finding that s. 85(1)(e.2) likely was applicable unless the TSO chose to respect a price-adjustment clause, the Directorate stated: [I]t is clear that the result of the transaction was that Madame conferred a benefit on Monsieur. … [Furthermore] it seems reasonable … to conclude that Madame desired to confer a benefit on Monsieur since, as sole director of the Corporation, it was she who chose to set the redemption value of the Class D shares at an amount lower than the FMV of the Class A shares transferred in consideration. ...
Miscellaneous severed letter
7 November 1991 Income Tax Severed Letter - Ontario R & D Superallowance and the Quebec R & D Tax Credit
7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...
SCC (summary)
Jean Coutu Group (PJC) Inc. v. Canada (Attorney General), 2016 SCC 55, [2016] 2 SCR 670 -- summary under Rectification & Rescission
Canada (Attorney General), 2016 SCC 55, [2016] 2 S.C.R. 670-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission rectification must give effect to common intention at time The taxpayer (“PJC Canada”), a Quebec corporation, implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. subsidiary (“PJC USA”), that overlooked foreign accrual property income considerations – so that interest generated to PJC USA on a loan that it made back to PJC Canada was included in PJC Canada’s income. ... In the AES case, the mistake consisted of a miscalculation in the adjusted cost base (“ACB”) of the transferred shares ― the procedure agreed to by the parties required the issuance and delivery of a note for an amount precisely equal to the shares’ ACB. ... [T]here is a fundamental difference between a contract under which one of a party’s prestations ― necessary for obtaining the intended tax result ― is to issue and deliver a note in an objectively calculable amount equal to the ACB of transferred shares, and a contract under which there is no obligation addressing FAPI, and no prestations agreed on that would prevent its fiscal consequences. …. ...