Search - 辐射监测仪 校准

. … [T]he coverage of the risk during the period covered by the premium will benefit the employee (or shareholder) if the employee's (or shareholder's) beneficiaries are the beneficiaries of the life insurance policy during that period. ...

For purposes of computing the s. 125.1(1) credit, should "adjusted business income" include such expense reimbursements, and should such reimbursements reduce Canco’s "labour cost" and "cost of manufacturing and processing labour "? ...

CCRA stated: [I]t seems to us that the arrangement between the employer, the trust and the insurer could resemble a health and welfare trust, provided that the conditions of … IT-85R2 are satisfied, including, among other things, that the employer does not have control over the use of trust funds. ...

X would be allocated his share of the capital gain – but that since the ACB of his partnership interest was increased to FMV under former s. 48(3) on his immigration and further increased by his capital contribution and his share of the capital gain, he would realize a capital loss on the partnership winding-up. ...

In those cases, the trust will be able to apply those expenses against its income other than taxable dividends, including against its net taxable capital gains … in order to allow for the maximum possible flow-through of the dividend tax credit to a beneficiary or beneficiaries, provided that this method does not contravene the legislative provisions relating to trusts or the trust agreement. ...

In this regard, it is important to note that it is not necessary for such advice to result in an actual acquisition or disposition for the fees paid for such advice to be deductible (see document # E 9607657). ...

. … [A] taxpayer cannot use this method to meet the traceability/linkage test if tracing can be done. ...

In finding that such amount would not be included in determining the corporate beneficiary's safe income or safe income on hand, CCRA indicated “that ‘safe income’ in respect of a share of a corporation means the net income of the corporation, determined in accordance with the Act and adjusted by paragraph 55(5)(b), (c) or (d) … that is attributable to that particular share during the holding period” so that, as the amount distributed to the corporation would not be included in its income by virtue of the operation of s. 104(13.1), such amount could not be included in its safe income. ...

The Directorate indicated that this question turned, having regard to s. 248(3)(f) and its stipulation that in Quebec that property in which a person has a right of ownership is deemed to be beneficially owned by the person, on “whether [their] share transfer agreement … resulted in a transfer of ownership of Monsieur's shares to Madame for the purposes of the Civil Code of Quebec” and that, if so, “the share transfer agreement will also have had the effect of changing the beneficial ownership of the shares for the purposes of the definition of ‘disposition’ in subsection 248(1).” ...

In its recitation of the facts, CRA accepted that by virtue of an election by the Trust pursuant to s. 107(2.001), s. 107(2.1) applied to this distribution, so that Trust realized deemed proceeds of $1,200.000 (resulting in a taxable capital gain of $99,950 being allocated to each Beneficiary under s. 104(21)), each Beneficiary was deemed to have acquired 100 shares at a cost of $200,000, and each Beneficiary disposed of the beneficiary’s capital interest in the Trust for proceeds of $100, which under s. 107(1)(a) had a deemed ACB equal to the cost amount of the distributed shares of $100 – so that no gain was realized on the disposition of each such capital interest. ...