Search - 阿里拍卖 司法拍卖

However, the CRA's long-standing position is that … the amount of the employment benefit calculated in paragraph 7(1)(a) generally relates to the duties performed during the year in which stock options are granted unless the facts, circumstances and relevant documents clearly demonstrate that the options were granted to compensate for future services. ...

However, the CRA's long-standing position is that … the amount of the employment benefit calculated in paragraph 7(1)(a) generally relates to the duties performed during the year in which stock options are granted unless the facts, circumstances and relevant documents clearly demonstrate that the options were granted to compensate for future services. ...

However … CRA's position is that the terms and conditions of a DSLP agreement generally cannot provide for the voluntary withdrawal from a plan by a participating employee. ...

2013 Ruling 2013-0488351R3- Conversion of a MFC to a MFT-- summary under Qualifying Exchange Summary Under Tax Topics- Income Tax Act- Section 132.2- Subsection 132.2(1)- Qualifying Exchange conversion of MFC to MFT and subtrust elimination The same (mutual fund corporation) taxpayer as for 2013 Ruling 2011-0395091R3 ("MFC to MFT Conversion") (immediately below) obtained essentially the same rulings for transactions which now reflected its acquisition of "Target" trust before the implementation of the merger of the taxpayer under s. 132.2 into REIT #1 (the internally-created replacement mutual fund trust) and the elimination of various subtrusts using s. 107.4 (or s. 248(1) – non-disposition) transfers and the s. 132.2 merger rules. ...

See detailed summary under s. 132.2(1) – qualifying exchange. ...

11 October 2013 APFF Roundtable, 2013-0495651C6 F- Revenu fractionné-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) streaming of non-split income to child discretionary beneficiary and split income to mother A discretionary family trust with Father, Mother and a 15-year old Child as beneficiaries, holds a building with two premises – the first leased to an arm's length tenant; and the second, to a professional corporation of Father and Mother. ...

After noting that the creation of a usufruct governed by the C.c.f. did not give rise to a deemed trust under s. 248(3), CRA stated (TaxInterpretations translation): … the Taxpayer is deemed to have disposed of the Immovable for consideration equal to its FMV and that her children were deemed to have acquired the property for the same amount, all in accordance with the provisions of paragraphs 69(1)(b) and (c). ...

After noting that the creation of a usufruct governed by the C.c.f. did not give rise to a deemed trust under s. 248(3), CRA stated (TaxInterpretations translation): … the Taxpayer is deemed to have disposed of the Immovable for consideration equal to its FMV and that her children were deemed to have acquired the property for the same amount, all in accordance with the provisions of paragraphs 69(1)(b) and (c). ...

For the purposes of the limitation under subsection 135(2), the amount that may be deducted by the taxpayer for the year is $20 million, being the lesser of: (a) all payments referred to in subsection 135(1), or $23 million ($17 million + $6 million); and (b) the portion of the taxpayer's income attributable to business done with members, being $20 million. …$3 million ($23 million- $20 million) can be carried forward to subsequent years under subsection 135(2.1). ...

20 March 2013 Internal T.I. 2013-0480201I7 F- Montants forfaitaires- XXXXXXXXXX-- summary under Qualifying Amount Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.2- Subsection 110.2(1)- Qualifying Amount portion of wage discrimination award that related to loss of salary (based on days’ worked) would be qualifying amount In discussing the treatment of lump sums paid to federal employees following a finding by the Human Rights Tribunal that a discriminatory practice had been committed at their workplace and pursuant to a settlement agreement concluded with the Treasury Board, CRA stated: [I]f the amounts paid … are intended to compensate for a loss of Workers' salaries, they meet the definition of "qualifying amount" under subsection 110.2(1). ...