Search - 深圳居住证 办理条件 最新政策

. … [A]ssume that a CFA (CFA 1) of a CCPC earned $100 in year 1 of the CCPC. … [T]he income inclusion would be completely offset by a deduction under subsection 91(4) because CFA 1 paid FAT of $35. ... By contrast, if CFA 1 paid FAT of only $21 because of the reduced US corporate rate, then the CCPC would recognize a $16 income inclusion in year 1.46 This $16 would be added to the CCPC’s ACB of the CFA 1 shares, pursuant to paragraph 92(1)(a). … [A]ssume that CFA 1 then repatriated the after-tax amount ($100 − $35 = $65) to the CCPC in year 2. Assuming that the amount was FAPI earned by CFA 1, the CCPC would be entitled to a full deduction under paragraph 113(1)(b) (that is, UFT ($35) × RTF − 1 (3) = $105). ...

. … [I]f the holding structure for a Canadian oil and gas company, such as in … Alta Energy … is migrated to Luxembourg at a time when there is neither an agreement nor a specific genuine intention to sell the shares of the Canadian company, no series should exist for the purposes of the application of the PPT. PPT broader than GAAR in using “one of the principal purposes” tests (p. 58) … Canada’s GAAR uses a principal purpose test, rather than a “one of the principal purposes” tests, to determine the presence of an avoidance transaction. ... This difference in standard can be illustrated by reference to … MIL Investments …. … [H]ad MIL Investments been decided under the PPT, [its factual] finding might mean that “one of the principal purposes” of the transactions was obtaining a treaty benefit, thereby triggering the application of the PPT. ...

The United States implemented broad-ranging tax reform, which included a "Transitional Tax" on most accumulated Earnings and Profits — essentially tax-based retained earnings — of many foreign corporations. [fn 2: US Internal Revenue Code ("IRC") § 965] … Canadian personal taxes and non-resident withholding tax are partially creditable against this Transitional Tax. [fn 3: IRC § 901, 965(g)] Americans who wish to generate Canadian tax to offset the Transitional Tax will need dividends paid in 2017. ...

(p. 1001) Canadian Inbound — Forward Subscription Method A U.S. corporation (USCo) may enter into a double-dip forward subscription financing arrangement with a Canadian operating company (Canco). ... As interest becomes payable it will, in effect, be retained by the Canadian acquisition company through directions on account of the subscription price for shares by LLC under the forward subscription agreement: Canco pays interest on debt to USCo; USCo directs that the amount be paid to LLC under its support obligations; and LLC redirects that Canco retain the amount on account of the subscription price for shares of Canco under the forward subscription agreement — Canco issues shares to LLC. ...

.] … The ACB denial rules can cause a parent's shares of its subsidiary to have mismatched tax attributes. ... Example illustrating punitive effect of CDA penalty rule (p. 6) [A]n individual owns all of the shares of a private corporation resident in Canada (“ Holdco ”). Holdco owns all of the shares of another Canadian-resident corporation (" Opco ") having a fair market value of $100, PUC of nil, and ACB of nil. ...

[fn 7: Kemp …3 DTC 1078 (Ex Ct) at paras 12-14; G ilhooly … [1945] CTC 203 (Ex Ct) at paras 22-23; … Hollinger … [1963] S.C.R. 131.] ... [fn 9: … 2012-0444091C6 …] Example of look-through approach (p. 3) [A] parent owns shares of a subsidiary valued at $40 and holds $50 of cash. ... [fn 11: Equal to (17% × $40 (value of subsidiary shares) + $40 (parent cash)) / $90 (total parent assets.] ...

Jack Silverson, Matias Milet, Christopher Anderson, Andrew Spiro, "Canada’s Reportable Transaction Rules: A Measured Approach to Adviser Reporting", Tax Notes International, Vol. 111, No. 29, July 15, 2023-- summary under Subparagraph 237.3(2)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(2)- Paragraph 237.2(3)(c)- Subparagraph 237.3(2)(c)(ii) expanded reportable transaction rules should not impose reporting obligations on lawyers who negotiate contractual protection for a conventional fee Under the revised reportable transaction rules, is a lawyer who assisted in negotiating contractual terms providing for contractual protection as contemplated by the contractual protection hallmark in s. 237.3(1) – reportable transaction – (c) and who charged a fee for such legal work obligated to report on the basis that the hours-based fee “is a fee … in respect of any … transaction … that is in respect of contractual protection,” as set out in s. s. 237.3(2)(c)(ii)? ... It would be inappropriate to give the phrase “in respect of” its widest possible meaning (which Nowegijick described as “words of the widest possible scope”) and, instead (having regard to this phrase having been interpreted more narrowly in other cases to accord with the context and purposes of the applicable provisions – see, e.g., Sarvanis, 2002 SCC 28, and Weyerhaeuser), a narrower interpretation of s. 237.3(2)(c)(ii), according with the context and purpose of the reportable transaction rules, is required. ...

Regulation 204.2(1) will require disclosure of any person who is a "beneficiary" of the trust …. Subsection 248(25) provides that certain persons are deemed to be "beneficially interested" in a trust, but it does not define "beneficiary" per se. … Propep … [stated] obiter, that a person should be regarded as a "beneficiary" throughout the Act if that person was "beneficially interested" in the trust. … For instance, the court says that "[a] person who has a contingent right to the capital or income of a trust is 'beneficially interested' for the purposes of the Act," …. The Propep interpretation has been adopted … [in] 2014-0538021C6 … with respect to the interpretation of subparagraph 55(5)(e)(ii) ...

(" Avenue ").] the Tax Court found that Avenue Business Campuses Ltd. ... (" Forever Dance ") and Fleming School of Dance Ltd. v. R., [2007] G.S.T.C. 152 (T.C.C.) (" Fleming "), where entrepreneurship and dance courses were accepted as vocational training.] ...

...