Search - 深圳居住证 办理条件 最新政策

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) place of contract not primary determinant The Directorate agreed that the taxpayer, which was a Canadian manufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Paragraph 94(3)(b) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(b) A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i)-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) funds earmarked for future projects of sister affiliates A CFA of Canco held funds generated from projects which were owned and operated by FA1, with the funds being "earmarked" for future investment in projects to be carried out by other CFAs of Canco. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Paragraph 8(b) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(b) property does not satisfy the “solely” test in Class 8(b) where it was necessary for the proper functioning of the building The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(5) building shell was a building or structure/ addition refers to extension of structure The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 5907(1.3)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1.3)- Paragraph 5907(1.3)(a) overview of FAT rules re consolidated US return with R&D credit Four U.S. ...

The mid-amble of subsection 13(29) … clearly indicates that the taxpayer must file a single election with its return for the “particular year” …. Once the Long-Term Project election has been filed with its return for the particular year, subsection 13(29) will apply in respect of the taxpayer’s “inclusion year” … [which g]enerally … will be the third and subsequent taxation years of the project where the taxpayer owns project property in that taxation year that has not yet otherwise become available for use. … … The … current … Form T1031 suggests that the form must be filed annually. … Form T1031 is currently under review. ...