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Technical Interpretation - External summary
12 September 2019 External T.I. 2019-0802301E5 - Annuity purchased from foreign pension -- summary under Subparagraph 56(1)(a)(i)
. … [T]he individual will be considered to have received a pension benefit equal to the fair market value of the annuity contract at the time the individual acquires it and must include this amount in their income under subparagraph 56(1)(a)(i). ...
Conference summary
11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 5, 2019-0820901C6 F - TFSA Exempt Contribution - Timing of contribution -- summary under Paragraph (c)
Y receives a survivor payment more than 30 days after making her contribution but within the rollover period, she may request the exercise of Ministerial discretion …. ...
Conference summary
11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 9, 2019-0813281C6 F - Pension splitting - RRIF deemed benefit -- summary under Subparagraph (a)(iii)
. … Comments made [in 2017] with respect to subsection 146(8.2) constitute an administrative concession and are applicable only with respect to that subsection. ...
Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Paragraph 7(3)(b)
Before addressing whether such payments were deductible under s. 32.1 or 9, the Directorate stated: [P]aragraph 7(3)(b) does not apply to prohibit a deduction for Canco’s PSP expenditures ….. ...
Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Income-Producing Purpose
. … [A]mounts invoiced by Parentco to a particular entity are based on the employee’s employer as at the grant date. ...
Conference summary
3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6 - Foreign taxes paid -- summary under Subsection 126(1)
CRA considers the date of payment of the foreign tax to be the relevant date for the purpose of section 126 – and, therefore, the date that the amount arose for the purpose of s. 261(2)(b). ...
Conference summary
3 December 2019 CTF Roundtable Q. 2, 2019-0824381C6 - Foreign taxes paid -- summary under Article 24
XXIV of the Canada-US Treaty – and took the view that this meant that a Canadian resident was subject to the “paid” requirement of s. 126. ...
Technical Interpretation - Internal summary
14 January 2020 Internal T.I. 2018-0785991I7 F - Subsection 86.1(2) -- summary under Subsection 86.1(2)
. … Furthermore, to the extent that the conditions in paragraphs 86.1(2)(e) and (f) have been satisfied and the Distribution was made in respect of all of the Common Shares of the capital stock of Parentco owned by the particular taxpayer at the time of the Distribution, it is our view that the Distribution is an eligible distribution to that taxpayer within the meaning of subsection 86.1(2). ...
Conference summary
11 October 2019 APFF Roundtable Q. 2, 2019-0812611C6 F - Résiliation d'un bail - Lease cancellation -- summary under Paragraph 20(1)(z)
. … In this case, the leasing activity does not appear to be free from personal aspects and it would be necessary to consider whether it is carried on in a sufficiently commercial manner so as to establish the existence of a source of income. ...
Conference summary
11 October 2019 APFF Roundtable Q. 3, 2019-0812621C6 F - Changement d’usage-impact sur l’exemption pour résidence principale -- summary under Subsection 45(3)
After referring to the initial residence unit as Unit 2 and the expanded unit as Unit 3, CRA stated: The taxpayer will therefore have to file two worksheets and two T2091 forms … if the taxpayer wishes to designate Unit 2 and Unit 3 as his principal residence for the applicable years. ...