Search - 辐射监测仪 校准

. … As such… withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

Before responding negatively, CRA stated (TaxInterpretations translation): … In this situation, 17% of the building is used in an active business carried on by XXXXXXXXXX. ...

. … Consequently, a testamentary trust cannot designate a benefit in its income tax return without ensuring that it constitutes an amount that would have otherwise been eligible under paragraph 60(j) for a beneficiary if the beneficiary had received it. ...

. … Usually…installation is seen as being performed in relation to a tangible property, such as a machine or equipment, and…installation should be the main activity of the project to qualify as an "installation project". ...

. … There is ample authority for the proposition that a trial judge is entitled to arrive at his own opinion as to value.” ...

. … In order to determine whether an expense incurred by an employee, which was not expressly provided for in an employment contract, is in fact an implicit requirement of an office or employment, the courts have considered whether the fact of failure to comply could result in termination of employment, poor evaluation of employee performance or other disciplinary action by the employer. ...

. … [I]t appears that the property described in your letter is not tools. ...

Before concluding that “subsection 13(7.1) should apply … so that an election under subsection 13(7.4) would not be required,” CRA noted: In a situation where subsection 13(7.1) does not apply, the election under subsection 13(7.4) can be made in order that the capital cost to the taxpayer of the property is reduced by the amount of government assistance received. ...

. … The expectations of a knowledgeable and prudent investor should be determined on the assumption that there would be no delay, postponement or default in the payment of dividends, that the dividends would be paid each year at a predetermined fixed or floating rate and that the proceeds to be received by the investor on the disposition of the share are the same amount the corporation received as consideration on the issue of the share. ...

. … [T]he GAAR should not apply to the situation in this case because subsections 103(1) and (1.1) are of sufficient breadth to adjust the income-sharing terms agreed between the partners of the partnership. ...