Search - 阿里拍卖 司法拍卖

. … [The] corporation's assets, particularly cash and longer-term investments, would require that type of analysis. ...

Given that s. 248(6) did not apply, and regarding the requirement in Reg. 4801(a)(i) that a class of units must be qualified for distribution to the public, CRA indicated that “this requirement would be met even if only one of the series of a class were qualified for distribution to the public since paragraph 4803(2)(a) … does not distinguish between series and class.” ...

(a) did not contain an adjustment similar to the adjustment in s. 111(1.1) for net capital loss, so that ¾ of the capital loss realized on January 14 was deducted from the Parentco (and the Amalco) CDA and 2/3 of the capital gain realized under s. 111(4)(e) was added to its CDA. ...

[See …] Kieboom.... ...

. … However, we are of the view that family ties may be more likely to give rise to the existence of a non-arm's length relationship between particular persons. ...

The CRA summary stated: The purpose test in 104(7.1) is not met, namely the main purpose of the proposed transactions is to reduce the administrative complexity of the Reduced Management Fee program & to enable the manager to effectively market the units to differing groups of Investors. ...

Furthermore, since the chartered Canadian bank is a resident of Canada, the GIC will not be a foreign property within the meaning of subsection 206(1) …. ...

On a going-forward basis the CRA is willing to provide assurance on the tax treatment of the discretionary dividend shares, but only in the context of a ruling request – and thus will no longer express its views on this matter in Technical Interpretations or Roundtable responses. ...

CRA further indicated that such “eligible medical expenses are not restricted to those paid in Canada or for medical services provided in Canada” – and that the insurer of the plan should determine whether this test in fact was being met. ...

. … If it is determined that the transfer of property was a sale for inadequate consideration rather than a gift, paragraph 69(1)(c) would not apply. ...