Search - 辐射监测仪 校准

. … [T]he fact that there is an issuance of shares of the capital stock of a transferee corporation, after the distribution of the property of the distributing corporation has been completed, would not be relevant for the purposes of the application of the definition of "permitted exchange" in subsection 55(1). ...

Finally … to the extent that the control of the transferee corporation was not acquired by the family trust, subparagraph 55(3.1)(b)(ii) would also not be applicable. ...

. … [T]he taxpayer could claim the METC for the medical expenses incurred in 2007, 2008 and 2009 in that the taxpayer no longer has the right to be reimbursed for these expenses as part of the group drug insurance plan. ...

After noting that “subparagraph 110(1)(d.01)(iii) provides that the gift must be made in the year and on or before the day that is 30 days after the day on which the taxpayer acquired the security” and that “A taxpayer who wishes to benefit from the deduction provided in paragraph 110(1)(d.1) must inter alia hold the securities … for a minimum period of two years,” CRA stated: [A] taxpayer who is only eligible for the deduction under paragraph 110(1)(d.1) will not be eligible for the deduction listed in paragraph 110(1)(d.01) because it will be impossible for the taxpayer to satisfy both the requirement of subparagraph 110(1)(d.01)(iii) and that of subparagraph 110(1)(d.1)(ii). ...

. … [T]he use of a motor vehicle for personal purposes generally includes travel between a taxpayer's home and the taxpayer’s place of business, unless it can be shown that the taxpayer’s principal place of business is the taxpayer’s home. ...

A further situation discussed was where a trust is established by the employer to acquire and hold shares of the corporation for employees, but allocations among the employees are entirely at the discretion of the trustees – so that CRA would consider that there is no agreement to acquire the shares until such discretion is exercised. ...

. … [S]ubsection 7(2) cannot apply any earlier than when a specific number of shares have been allocated to an identifiable employee pursuant to a legally binding agreement to issue or sell shares. ...

. … [I]n the situation you described, an individual who resides in a prescribed northern or intermediate zone for a period of at least six months and who has a 35-day work cycle in the said zone followed by an 8-day leave in his other residence at XXXXXXXXXX would be entitled to the deduction provided for in section 110.7. ...

…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...

. – which, in turn, could engage s. 74.1(1) where the subscriber was X’s spouse. ...