Search - 阿里拍卖 司法拍卖

. … [T]he CRA has expanded its administrative position to the case where the property is utilized by a person who is related to a beneficiary as the property is, in that situation, a personal use property of the trust. ...

. … DC owns property ("Property1") which was rezoned…. From XX to XX, XX lots of Property1 have been severed and sold. ...

20 February 2014 External T.I. 2012-0460191E5- Permanent establishment in a province-- summary under Subsection 400(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 400- Subsection 400(2) general factors In the course of making general comments on the meaning of permanent establishment, CRA quoted from 2011-0395331I7, including the following: In … Dudney [2000] 2 CTC 56, a "fixed place of business" for the purpose of Article XIV of the Canada-U.S. ...

Furthermore, we generally consider the rates set out in section 7306 … to be reasonable for the purpose of calculating an allowance for the use of a motor vehicle referred to in paragraph 6(1)(b). ...

CRA stated: [T]he Technical Explanation to the 2007 Protocol states that subparagraph 2(a) provides a safe harbour rule that is applied on a calendar year basis …. ...

. … [A] distribution of income from a SIFT Trust is deemed to be a dividend pursuant to subsection 104(16)… and is similarly treated as a dividend for the purposes of the Treaty pursuant to the 2007 Protocol Annex B in regards to paragraph 3 of article X. ...

After noting that the contract with the union “must show that the contributions were paid pursuant to a PHSP within the meaning of section 20.01,” CRA stated: [A] contribution to a plan that qualifies as a PHSP could result in a deduction in computing the income from a business of the individual, who is a self-employed business owner, if all the conditions set out in subsection 20.01(1) were also met and to the extent that such an expense was reasonable in the circumstances. ­ ...

. … In order to determine the place where an Indian lives, we usually analyze whether the Indian lives on a reserve, in a domestic establishment that is his or her main place of residence and the center of his or her daily activities. ...

In the course of general comments, CRA stated: [T]he words "in respect of" [in s. 248(1) – "retiring allowance"] have been held… to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the receipt was compensation for the loss of employment. ...

12 January 2015 Internal T.I. 2014-0560421I7- FX losses on CFA wind-up-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) s. 40(3.6) not specifically ousted on s. 88(3) winding-up – but no affiliation after disposition In 2014-0538591I7, the Directorate indicated that s. 40(3.6) did not apply to deny a loss realized on the winding-up of a controlled foreign affiliate because (1) s. 69(5)(d) specifically ousts the application of s. 40(3.6) respecting property (the CFA's shares) disposed of on a winding-up, and (2) it is unlikely that under the foreign corporate law the CFA would be considered to still exist immediately after that disposition. ...