Search - 赤峰 二中 初中学区划分 2005

In December 2005, the RRSP sold the shares for $1, and the corporation was insolvent. ... Given … Byram, we do not believe that Mr. A's loss should be deemed to be nil solely because the Corporation's shares were acquired by the RRSP and not personally by Mr. ...

13 February 2017 Internal T.I. 2015-0568011I7- Classification of Florida LLLP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Florida real estate LLLPs were corporations (subject to transitional relief) An LP governed by provincial law and with Canadian-resident members, invested as a limited partner in two LLLPs governed (“Florida-LLLP-1” and “Florida-LLLP-2”) governed by the Florida Revised Uniform Limited Partnership Act of 2005 (“FRULPA”), which provided: An LLLP is an entity distinct from its Partners that has a perpetual duration. ... The Directorate indicated that, consistently with 2016-0642051C6, a Florida LLLP generally should be considered as a corporation given “the existence of a separate legal personality that is recognized under the FRULPA – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the limitation of liability afforded to all of their members.” ...

Quebec (2010 EXP-2783) contributed $5,970 to his spouse's RRSP in 2005, which he deducted, and a year later the amount was withdrawn. ... [T]he deductions [under s. 153(1)(j)] are … made from the lump sum payment and designated as being for the account of the person receiving the amount, being the RRSP annuitant. ...

p=37586#Q7b">19 June 2015 STEP Roundtable, oral Q.7(b) Assume in January 2005, Mr. ... Therefore, Trust would be deemed to be resident in Canada for the 2015 taxation year. … [S]ubsection 94(10) will deem Mr. ... Z, a previous long term resident of Canada, became a non-resident in January 2007, in July 2010 made a contribution to a non-resident trust (the "Trust2") and in March 2015, became a resident of Canada – and that Trust2 has Canadian resident beneficiaries who are not successor beneficiaries. ...

Rockies Corp, 2005 DTC 289) that "a corporation may opt for whichever instalment method under paragraph 157(1)(a) that it wishes, regardless of the instalment method that is deemed by subsection 161(4.1) to have been used for purposes of computing the corporation's interest in respect of unpaid or late instalments," CRA stated that "a corporation's functional currency election…does not hinder its ability to choose…[an] instalment method under paragraph 157(1)(a)," stated that it "will not consider the use of either the First Instalment Base Method or the Second Instalment Base Method where a reporter's Total EFC Instalments [the total required instalments, as converted to the EFC] using the respective instalment method exceed the reporter's EFC Taxes Payable for the year," and that it was appropriate "that each assessment of the CAD Taxes Payable of a functional currency reporter…[use] the instalment method that gives rise to the least amount of CAD Taxes Payable" – so that when re-determining the CAD Taxes Payable for a particular taxation year as a result of a s. 111(1)(a) deduction of a subsequent year's loss, the same instalment method that was originally used for the particular year is not required to be used to recalculate the CAD Taxes Payable. ...