Search - 辐射监测仪 校准

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer would generate imputed interest and FAPI to CFA, plus s. 80.4(2) application to sister A wholly-owned foreign subsidiary (FS) of CanCo uses funds generated from its operations to make a non-interest bearing loan to a foreign borrower (FB), which is wholly owned by the foreign parent (FP) of CanCo. ...

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer generated double tax (FAPI and Pt. ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 1, 2023-0976911C6 F- CELIAPP- Changement d'usage / FHSA- Change in use-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal- Paragraph (d) a recent change of a home from rental to principal-residence use cannot ground an FHSA withdrawal An individual purchased a single-family home in 2020 for rental to a third party, in May 2023 opened and contributed $8,000 to an FHSA and then, after the tenant vacated, moved into the home as his principal place of residence on November 1, 2023, so that there was a deemed disposition and reacquisition of the property pursuant to s. 45(1)(a) on that date. ...

5 March 2024 External T.I. 2023-0962831E5- Active business income – Income from solar panels-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business income from solar array panel might not be income from property, so that there was no SIB The sole business activity of a Canadian-controlled private corporation (the “Corporation”) was to build a small utility-scale solar array on bare land and sell the electricity that was generated to a local utility service under the terms of a long-term contract. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Subparagraph 84.1(2.32)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(i) retention of special voting shares by parent would preclude access to s. 84.1(2)(e) exception A parent wishes to access the s. 84.1(2.31) or (2.32) rules regarding a transfer of Parent Inc. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Subparagraph 84.1(2.32)(f)(ii) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(f)- Subparagraph 84.1(2.32)(f)(ii) s. 84.1(2.32)(f)(ii) not satisfied if substantial unpaid purchase price at end of 10 years A parent wishes to access the s. 84.1(2.32) rules regarding a transfer of the shares of Parent Inc. ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...

11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp S. 84.1(2.3)(a)(i), as part of the former (private-member bill) intergenerational business transfer rules, provided that if, otherwise than by reason of death, the children’s purchaser corporation disposed of the subject corporation shares within 60 months of their purchase, the exception in s. 84.1(2)(e) from the application of s. 84.1 was deemed never to have applied. 2022-0953991E5 F indicated that, consequently, if the purchaser corporation amalgamated, within the 60-month period, with the subject corporation, then the resulting disposition pursuant to s. 87(11)(a) by the purchaser of the subject shares would engage the s. 84.1(2.3)(a)(i) exclusion. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) place of contract not primary determinant The Directorate agreed that the taxpayer, which was a Canadian manufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...