Search - 赤峰 二中 初中学区划分 2005

The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor.... 1.48 For an example of a case where the taxpayer did not own shares directly in the debtor corporation but a sufficient connection was shown to exist for the exception described in ¶ 1.44(a) to apply, see Alessandro v The Queen, 2007 TCC 411 &d1=&d2=&su=0"> 2007 TCC 411; 2007 DTC 1373 (TCC). For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592 &d1=&d2=&su=0"> 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163 "> 2005 FCA 163, 2005 DTC 5281). ...

In 2005, Mr. X died and the house was transferred to a spousal trust for Mrs. ... X had not died (and if he had sold his house in 2005), he could have designated it as his principal residence for any of the years 1995 to 2005 inclusive. ... (The house was, of course, owned by the trust in 2005 in any event.) This means that the years that the trust must include in variable C in the principal residence exemption formula in ¶ 2.17- 2.26 are 1995 to 2011 inclusive. ...

Corporation A: realized a capital gain of $100,000 in its 2005 tax year, of which the non-taxable portion, $50,000, was added to its CDA; and as a result of the disposition of an eligible capital property in its 2012 tax year, included the amount of $25,000 in its income pursuant to paragraph 14(1)(b) and added that amount to its CDA. ... Component 1 = NIL (because Component 1 cannot be a negative amount)... Component 3 = $25,000... Component 4 = $40,000... Component 1 + Component 3 + Component 4 = $65,000 In the first tax year after amalgamation, Amalco realizes a capital gain of $90,000, the non-taxable portion of which is $45,000.... $25,000 of the non-taxable portion of the capital gain must first be applied to extinguish the notional negative balance of the capital gain component of the CDA of Amalco (Component 1 of the CDA) before the remaining $20,000 can be applied to increase the CDA balance of Amalco.... ...