Search - 赤峰 二中 初中学区划分 2005

Rod Butcher, "GST and Pensions- Back to the Future", GST & Commodity Tax, March 2005, p. 9.-- summary under Section 261.01 Summary Under Tax Topics- Excise Tax Act- Section 261.01 ...

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.-- summary under Paragraph 20(1)(r) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) Services requirement (pp. 486-7) Consistent with contributions to other pension arrangements, employer contributions to an RCA are deductible in the year they are paid. ... [fn 33: CRA document no. 2004-0082991E5, January 5, 2005.] ...

…In another example, based on the Bank of Scotland case [fn 233: … Ministre de l’Econimie v. ... …[T]he analysis in the commentary appears to suggest that the PPT could also apply to transactions or arrangements like those in Del Commercial Properties [fn 239: C Memo 1999-411 • aff'd 251 F.3d 210 (DC Cir. 2001), denying treaty benefits on the basis of a domestic substance-over-form doctrine….] ... [fn 253: … Yanko-Weiss v. Holon Assessing Office (2007), 10 TLR 524 (Tel Aviv-Yafo DC) denying treaty benefits on the basis of an implicit anti-abuse principle.] ...

Angelo Nikolakakis, Alain Léonard, "The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financing Issues, and Repatriation of Profits", 2005 Conference Report, c. 21, p. 21:8.-- summary under Subsection 212.1(4) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(4) In step 1 of figure 4, Bidder transfers Target to Bidder Forco in exchange for a promissory note ("the Bidder Forco reorganization note") with a face amount equal to the fair market value (FMV) of Target. Section 212.1 does not apply because this is not a transfer of the shares of one corporation resident in Canada to another, and there is no gain from the disposition of the Target shares because they were just acquired in a taxable arm's-length transaction. 30 In step 2, Bidder transfers Bidder Forco shares and the Bidder Forco reorganization note to Bidder Canco in | exchange for Bidder Canco shares and a promissory note ("the Bidder Canco capital note") in an appropriate combination. ...

No general policy against surplus-stripping (p. 143) [T]he courts have found that there is no overarching policy against surplus stripping [citing: Evans, 2005 TCC 684, at para. 30, McMullen, 2007 TCC 16, Copthorne, 2011 SCC 63 at para. 118, Gwartz, 2013 TCC 86, at paras. 50-51, MacDonald, 2012 TCC 123, rev'd 2013 FCA 110, cf. ...

. … [I]n British Columbia, the restriction only applies to "a record evidencing indebtedness of the person to whom shares are to be issued" (i.e., a promissory note issued by the subscriber)…. ... [fn 13: For a more comprehensive discussion of the cases see Greg Johnson, "Recent Developments of Interest to Tax Practitioners", 2005 Prairie Provinces Tax Conference (Toronto: Canadian Tax Foundation, 2005), 18:1-27 at 18:4-8.] ... MNR [fn 16: …92 D.T.C. 2123…] ….. Nullification was used in the recent Federal Court of Appeal case St Arnaud v. ...

. … [I]n British Columbia,, the restriction only applies to "a record evidencing indebtedness of the person to whom shares are to be issued" (i.e., a promissory note issued by the subscriber)…. ... [fn 13: For a more comprehensive discussion of the cases see Greg Johnson, "Recent Developments of Interest to Tax Practitioners", 2005 Prairie Provinces Tax Conference (Toronto: Canadian Tax Foundation, 2005), 18:1-27 at 18:4-8.] ... MNR [fn 16: …92 D.T.C. 2123…] ….. Nullification was used in the recent Federal Court of Appeal case St Arnaud v. ...

. … In a 2005 technical interpretation, [CRA] took the position that a service provider whose principal business included the maintenance of account records did not satisfy the test because "[the service provider's] services do not include time spent on the custody of securities, the collection and remittance of income, and the right to buy and sell on [its] own judgment on behalf of some clients without reference to those clients. [F.n. 382 … 2005-0124131E5.] ...

(" Avenue ").] the Tax Court found that Avenue Business Campuses Ltd. ... R., [2005] G.S.T.C. 176 (T.C.C.), Forever Dance Inc. v. R., [2003] G.S.T.C. 152 (T.C.C.) (" Forever Dance ") and Fleming School of Dance Ltd. v. R., [2007] G.S.T.C. 152 (T.C.C.) ...

Canada Customs & Revenue Agency, 2004 FC 573 at ¶33, aff'd 2005 FCA 68.] ...