Search - 辐射监测仪 校准
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Conference summary
14 May 2015 CLHIA Roundtable Q. 5, 2015-0573821C6 - Safe income -- summary under Paragraph 55(2.1)(c)
. … However, the portion of such premiums that does not contribute to the increase of the cash surrender value of the Policy at that time will not be on hand at the safe income determination time and would therefore reduce the amount of safe income that could reasonably be considered to contribute, immediately before the Dividend-in-Kind, to the accrued capital gain on the Opco shares on which that dividend is received. ...
Ruling summary
2012 Ruling 2011-0392041R3 - Incorporation of a Professional Partnership -- summary under Subsection 85(3)
See summary under s. 125(7) – specified partnership income. No rulings are provided on ss. 85(2) and (3). ...
Technical Interpretation - External summary
8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité -- summary under Income-Producing Purpose
. … [T]his policy was not acquired with a view to earning income from the business. ...
Technical Interpretation - External summary
8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité -- summary under Exempt Receipts/Business
. … [T]his policy was not acquired with a view to earning income from the business. ...
Technical Interpretation - External summary
11 June 2015 External T.I. 2014-0522641E5 F - Usufruct -- summary under Subsection 108(7)
See summaries under s. 73(3) and s. 110.6(1) – qualified farm or fishing property. ...
Technical Interpretation - External summary
1 May 2014 External T.I. 2013-0494981E5 F - De Jure Control -- summary under Subparagraph 251(2)(b)(i)
. … [T]his approach should be preferred, in any situation similar to that described in Scenario 3, for establishing who has de jure control of a corporation. ...
Technical Interpretation - Internal summary
30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund -- summary under Subparagraph 152(4)(a)(i)
. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...
Technical Interpretation - External summary
20 August 2015 External T.I. 2015-0581681E5 F - Non-resident trust rules -- summary under Connected Contributor
. … After paraphrasing the definitions of "resident contributor," "contributor" and "resident beneficiary" (which latter definition referenced a "connected contributor to the trust,") CRA stated: Under subsection 94(1), a "connected contributor" includes any contributor to the trust at a particular time other than a person all of whose contributions to the trust made at or before the particular time were made at a non-resident time of the person as defined in subsection 94(1). ...
Ruling summary
2014 Ruling 2013-0514561R3 - Payment in lieu of continued PHSP coverage -- summary under Paragraph 6(1)(a)
Proposed transactions Former employees (and dependants where relevant) will receive under a CCAA Plan one or more payments out of the available cash pool of Canco on account of their claim for termination of coverage under the Plans in an amount equal to their pro-rata share of the aggregate settlement amount – except that claims under a Life insurance plan will be paid separately. ...
Technical Interpretation - Internal summary
13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices -- summary under Subparagraph 6(1)(a)(i)
. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...