Search - 辐射监测仪 校准

Regarding the deductibility of the pilot’s meal expenses, CRA stated: [O]ne of the conditions for claiming a deduction for meals under paragraph 8(1)(g) … is that an employee must generally be away from home overnight in the performance of their employment duties. ...

However, the registered charity would be an “exempt person,” which is defined in s. 94(1) to include a person exempted under s. 149(1), and thus would be excluded from being a “resident beneficiary” (under the preamble of that term’s definition) – so that s. 94 would not apply to the trust. ...

CRA was then approached, who determined that GAAR applied to the rollout of the Holdings shares to Holdco, so that s. 104(5.8) should be treated as applying to the capital property of Trust 2 upon the (now imminent) occurrence of the 21 st anniversary of the formation of Trust 1 so as to result in a deemed disposition of such property pursuant to s. 104(4)(b)(ii) – and the Directorate so ruled in this ruling letter. ...

CRA stated: The CRA’s view remains that subsection 15(1) … applies when a non-resident corporation confers a benefit in the form of making available to its non-resident shareholder or to an individual that does not deal at arm’s length with the non-resident shareholder (such as their family members) a property located in Canada. ...

26 June 2020 External T.I. 2017-0688121E5 F- Déductibilité des intérêts et pénalités imposées sur les taxes foncières-- summary under Section 67.6 Summary Under Tax Topics- Income Tax Act- Section 67.6 tardiness “penalty” added by municipality to unpaid property taxes came within s. 67.6 After indicating that “interest charged on an unpaid balance of property taxes will be deductible if the property taxes themselves are deductible,” CRA indicated regarding a tardiness penalty of 0.5% per month of the unpaid taxes added by a municipality pursuant to s. 250.1 of the Act respecting municipal taxation ("AMT"): [S]ection 67.6 … prohibits the deduction in computing income of any penalty imposed under the laws of a country or a political subdivision thereof. ...

. … [T]his allowance is deemed not to be reasonable under subparagraph 6(1)(b)(x) because the use of the vehicle is not determined solely on the basis of the number of kilometres driven to perform the duties of the employment. ...

The effect of C of the FAPI formula was that the OIFP rules generated FAPI to CFA, and Canco then picked up its share of such FAPI – and this combined operation of the FAPI and OIFP rules was not affected by dividends paid by FA to the CFA (inter-FA dividends are excluded form FAPI) nor was it affected by any dividends paid by CFA to Canco. ...

. … In its review, the Income Tax Rulings Directorate will have to consult internal stakeholders and the whole process may take some time. ...

. … Since a “branch” of a non-resident corporation is not a separate legal entity from the non-resident corporation, payments to a Canadian branch of a non-resident corporation made in respect of services provided in Canada are subject to Regulation 105 withholding.... ...

11 March 2024 External T.I. 2022-0939331E5- Workers’ Compensation Settlement-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no withholding on WSIA worker’s compensation CRA noted that since s. 56(1)(v) requires an income inclusion for "compensation received under an employees’ or workers’ compensation law … of a province in respect of an injury,” compensation received by the estate of an injured worker pursuant to the Ontario Workplace Safety and Insurance Act was includible in its income (and deductible in computing its taxable income.) ...