Search - 润华 最新动态 2025

CRA noted that because the $20M of property was acquired before 2025, it would be a Class 43.2 property (50% CCA rate) rather than a Class 43.1 property (30% CCA rate) even though no CCA could be claimed until 2025 due to the available-for-use rules. Its CCA claim for 2025 would be calculated as follows: Capital cost $20M AII per Reg. 1100(2) – A- (c)(ii) (i.e., 1/2 X $20M) $10M Subtotal $30M CCA (50% Class 43.2 rate) $15M The “clean tech” ITC under s. 127.45(1) for 2027 would be 20% of the capital cost of $20M, or $4M. ... The CCA claim for 2027 would consist of a further $0.25M for the Class 43.2 property plus CCA regarding the $10M Class 43.1 acquisition calculated as follows: Capital cost $10M AII per Reg. 1100(2) – A- (b)(iii) (i.e., 5/6 X $10M) $8.33M Subtotal $18.33M CCA (30% Class 43.2 rate) $5.5M The clean tech ITC for 2027 would be 20% of the capital cost of $10M, or $2M. ...

Q.3.1 Taxpayer dies in March 2025 and Joan subsequently causes Purchaser Corporation to sell the Subject Shares to an arm’s length purchaser (ALP) for proceeds of $3 million (ALP Disposition). ... Regarding both the Q.3.1 and Q.3.2 scenarios, what would be the impact on the tax positions of Taxpayer and Purchaser Corporation in 2021 and 2025 if 84.1(2.3)(a) applied? ... However, Taxpayer would be deemed, for the purposes of section 84.1 …, to have disposed of the Subject Shares to the person who acquired them from Purchaser Corporation (himself). … [W]e are prepared to apply this provision such that, if Taxpayer had disposed of the Subject Shares directly to the subsequent purchaser and section 84.1 … would not have applied to that disposition, the First Disposition will not be subject to section 84.1 …. ...

., until May 31, 2025) exemption to a ban (imposed effective June 1, 2022) on OEO Dealers from being paid trailer fees by a mutual fund or its manager, to receive a trailing commission from the mutual fund or dealer in order to facilitate the OEO Dealer paying a rebate of such amount to its clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances … it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...

., until May 31, 2025) from this prohibition in order to facilitate the OEO Dealer in paying a rebate of such amounts to their clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances … it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...

., the actual capital cost grossed-up to $15,000,000 and multiplied by the 50% Class 43.2 rate); It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund; It claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate); It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. In 2025, the capital cost of the property will have been reduced (pursuant to s. 13(7.1)(e)) by the two federal tax credits claimed and (pursuant to s. 13(7)(f)) by the NS CITC “assistance” claimed, i.e., to $4,500.000. ...