Search - 阿里拍卖 司法拍卖

. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

. … [T]he U.S. tax paid by Usco on its share of the portion of the gain computed pursuant to the Code from the disposition of the Consideration Property by the Partnership that could reasonably be regarded as the gain and/or recaptured depreciation determined pursuant to the Code that was deferred on the disposition of the Rental Property by the Partnership would qualify as FAT. ...

. … [W]here an employee incurs meals expenses for travel outside the municipality or metropolitan area [of the employer's establishment] and the employee is reimbursed by the employer, this amount is not included in the calculation of employment income because this travel mainly benefits the employer. ...

. … Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...

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27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subparagraph 53(2)(c)(v) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(c)- Subparagraph 53(2)(c)(v) loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. ...

27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subsection 40(3.1) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. ...

. … The fact that property was received from the Vendor in a fair market value purchase will not be relevant... ...

. … MFDA..or…AMF…), only the fund manager would be required to file T5008 slips with the CRA and provide a copy of the T5008 slip to the client. ...

Opinion S. 104(4) will not apply to the New Trusts by reason of (g) of s. 108(1) – trust. ...