Search - 深圳居住证 办理条件 最新政策

19 December 1991 External T.I. 9127875 F- Tuition Tax Credit — Non-refundable Application Fee Unedited CRA Tags 118.5(1)(a) 912787 Dear 19(1): We are writing in reply to your letter of October 2, 1991, wherein you  requested our views on the meaning of the word "enrolled" in the context of paragraph 118.5(1)(a) of the Income Tax Act (the Act) as it relates to the following situation: A college situated in Canada, charges an application fee of $400.  ...

8 February 2012 External T.I. 2011-0425411E5- Change in fiscal period & transitional reserve Unedited CRA Tags 34.2(1), 34.2(2), (4),(11), (12) Principal Issues: (1) Periods upon which ASPA is computed under paragraph (a) of the definition of ASPA. (2) Transitional reserve deduction under paragraph 34.2(11)(a) where a corporation has a change in fiscal periods. ... Our Comments ASPA, as defined under paragraph (a) of the ASPA definition in subsection 34.2(1), is determined by the formula [(A- B) × C/D]- (E + F). ...

19 January 2012 External T.I. 2011-0425891E5- Art 19 Canada-China Treaty & Immigration Unedited CRA Tags Canada-China Treaty Art. 19, SC 1986, c 48, Part III. ... Position: 1 & 2. Questions of fact specific to the individual. Absent evidence to the contrary, applications for permanent residence can be viewed as strong evidence of an intent to go beyond merely visiting Canada and that an individual's presence in Canada is also meant to establish lasting residential ties. Reasons: 1 & 2. Immigration status is informative but not determinative of residency and residency-related issues for tax purposes. ...

5 December 2005 External T.I. 2005-0155331E5- XXXXXXXXXX 2006 Meeting- Q & A's Unedited CRA Tags 18(4) 95(6) Principal Issues: Questions & Answers provided by Wayne Adams at 2006 XXXXXXXXXX Meeting Limited partnerships and thin capitalization Various questions re 95(6) Reverse hybrids and treaty Position: See body of memo Reasons: See body of memo On October 24, 2006, Wayne Adams, Director General of the Income Tax Rulings Directorate, Canada Revenue Agency, attended the XXXXXXXXXX meeting and responded to the following questions: 1. ... The judgment contained the following relevant passage: ".. I am not prepared to say that because a U.S. tax saving that is greater than the Canadian tax saving is envisaged or achieved by a Canadian tax avoidance scheme this in itself takes the transaction outside the ambit of section 245. ...

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance CRA Tags 70(6) 73(1.01) 73(1.02) Principal Issues: Scenario whereby income or capital from a proposed spousal trust was to be used to pay life insurance premiums on spouse's life- would this disqualify trust from ever being a spousal trust eligible for rollover of property upon creation of the trust Position: Trust would not qualify for the rollover- would not be a "spousal trust" from inception Reasons: We remain of the view that this would result in someone other than the spouse having use of the trust capital or income while the spouse is alive. ...

16 June 2010 External T.I. 2010-0361221E5- Wheelchair & bath cushion as medical expense Unedited CRA Tags 118.2(2)(i) Principal Issues: 1. ...

2 June 2006 External T.I. 2006-0173251E5- Reward Points / Airplane ticket Unedited CRA Tags 118.1 Principal Issues: Whether the donation of an airplane ticket that has been acquired by redeeming reward points qualifies as a gift for the purposes of section 118.1 of the Income Tax Act. ...

25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1) Unedited CRA Tags 125 Principal Issues: Whether the business limit that can be assigned under subsection 125(3.2) is before or after the application of subsection 125(5.1). ...

E9820215- REPORTING & WITHHOLDING- RETIRING ALLOWANCE Unedited CRA Tags 153(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

E9823475- MANAGEMENT FEES & SWAPS Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...