Search - 阿里拍卖 司法拍卖

. … CRA considers that "principal" refers to the person's chief or main business activity. ...

If the Fund had not acquired any additional units … the contribution to the Trust would not increase the Fund's ACB of its capital interest in the Trust, notwithstanding that it would increase the FMV of its capital interest in the Trust. ...

After noting in its summary that “ Tremblay... contains a strong dissent based on... ...

Consequently, whether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) – or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...

In finding that the purported testamentary trust would not qualify because its contingent interest in the inter vivos trust was not property contributed to it by the deceased, CRA stated: [W]hether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) – or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...

In that regard … the scope of the deemed trust cannot be limited by the fact that a secured creditor could in certain circumstances be equated with a third party purchaser. ...

. … CanOpco's legal obligation to pay interest expired on the day it obtained protection from its creditors under the CCAA. ...

. … [T]he CRA does not intend to provide any administrative relief to the non-resident surviving spouse who does not hold or cannot obtain a SIN so as to effect a tax-free transfer to an RRSP or a RRIF, as described above. ...

Parent makes a daylight loan to a partnership (New LP) formed by the Profitcos (Parent and two wholly-owned subsidiaries – Aco and CCo, with another wholly-owned subsidiary, BCo as the GP). ...

. … [T]o be eligible as medical expenses for the purposes of the METC, the expenses must be incurred, paid for, and evidenced by a receipt within the same 12-month period ending in a taxation year. ...