Search - 辐射监测仪校准 | Page 281

14 January 2004 Internal T.I. 2003-0049531I7 F - Valeur de rachat - police d'assurance -- summary under Paragraph (b)

" In indicating that an investment allowance might not be allowed for such a policy, CRA stated: [T]he only assets issued by a corporation that is a financial institution that qualify for the investment allowance … are a share of the financial institution or a long-term debt. ...

22 January 2004 External T.I. 2003-0006191E5 F - Frais et montant reçus lors de poursuite -- summary under Subsection 15(1)

. … [T]he fees paid by the corporation for the principal shareholder should be included in the principal shareholder's income pursuant to subsection 15(1). ...

26 January 2004 External T.I. 2003 - 0047961E5 F - Part IV Circularity -- summary under Paragraph 186(1)(b)

Second, a corporation that receives an eligible dividend from a payer corporation is subject to Part IV tax whether or not the payer corporation receives the DR – so that if CCRA allowed a corporation to waive a DR, this would have no effect on the Part IV tax payable by the other corporation. ...

7 January 2004 External T.I. 2003-0032501E5 F - Transitional Rules/Allègement transitoire -- summary under Subsection 112(3)

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

22 January 2004 Internal T.I. 2003-0047561I7 F - Effet de la délégation puis de la subrogation -- summary under Subparagraph 40(2)(g)(ii)

In this regard, the Directorate stated: [T]he provisions of paragraph 40(2)(g)(ii), that deem a loss on the disposition of certain debt obligations to be nil, do not apply since the … debt obligation was interest-bearing, as the taxpayer was subrogated by the financial institution as to the interest-bearing mortgage ...

2 February 2004 External T.I. 2003-0050241E5 F - Déductibilité des intérêts -- summary under Subparagraph 20(1)(c)(i)

. … [T]he provisions of section 22 of the Regulation will not, in and of themselves, prevent the deduction of interest on money borrowed to acquire common shares of a QBIC if there is otherwise a reasonable expectation, at the time the shares are acquired, that the holder of the common shares will receive dividends. ...

27 January 2004 External T.I. 2003-0048891E5 F -- summary under Subparagraph 20(1)(c)(i)

. … [T]he direct use of the borrowed money is for personal purposes, which is not an eligible use. ...

29 January 2004 External T.I. 2003-0040631E5 F - Rente de bienfaisance : contrat ou fiducie -- summary under Subsection 75(2)

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...

20 February 2004 External T.I. 2003-0035361E5 F - Chantier particulier - travail temporaire -- summary under Subparagraph 6(6)(a)(i)

In those circumstances, we doubt that the work of the employees is of a temporary nature and, in our view, the … premium could not be excluded from the employees' income by virtue of subsection 6(6). ...

30 January 2004 Internal T.I. 2003-0037191I7 F - Fabrication /sous-traitants/frais de gestion -- summary under Paragraph (a)

The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the Persons likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

You are here

Search - 辐射监测仪校准

Filter by Type: