Search - 阿里拍卖 司法拍卖

After noting that it was necessary to report the preconverted living unit and the expanded unit separately in claiming the principal residence exemption, CRA stated: … [A]n allocation of the adjusted cost base ("ACB") and the proceeds of disposition of a property based on the size of each unit is, in some cases, that of a reasonable allocation. ...

. … [T]his subsection can apply to an amount of interest received from a trust and included in computing the income of a specified individual, to the extent that all other conditions for application of that paragraph are satisfied. ...

CRA responded: A corporate beneficiary of a trust in respect of which a [s. 104(19)] designation is made is … deemed to have received the dividend for the purposes of section 55 and can benefit from the safe income exception in paragraph 55(2.1)(c). ...

. … [T]he fact that provincial insurance law may exempt a charitable organization from the application of certain legislative requirements with respect to the issuance of charitable gift annuities does not amount to the organization being licensed or otherwise authorized under that law to carry on an annuities business in Canada. ...

The bonuses described in examples 4 and 6 of the … Folio [S3-F10-C3] and the rebates of mutual fund commissions discussed at paragraphs 3.36 and 3.37 are (or are analogous to) a return on the amounts invested from the registered plan with the financial institution. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

CRA responded: [I]n the situation where the Spouse is named as the sole beneficiary of an unmatured RRSP or RRIF … in the RRSP or RRIF contract, the T4RSP or T4RIF slip will be issued in the Spouse's name where all of the following conditions are satisfied: the Spouse is named as beneficiary in the RRSP or RRIF contract (Footnote 13) of all the property held in the RRSP or RRIF; the entire refund of premiums in the case of an RRSP, or the eligible amount of the benefit designated under subsection 146.3(6.11) in the case of a RRIF, is transferred directly, under paragraph 60(l), to an RRSP or RRIF under which the Spouse is the annuitant or the funds are used to purchase an eligible annuity under which the Spouse is the annuitant; before December 31 of the year following the year of death, all property held in the RRSP or RRIF is distributed. ...

Before concluding that it would “generally consider emergency government assistance, including assistance from provinces and municipalities, directly related to COVID-19 to be an extraordinary item,” but that this would include “COVID-19-related government assistance … to the extent that it replaces or is meant to replace normal or recurring government assistance,” the Directorate stated: Generally, we would expect extraordinary items to meet all three of the following characteristics: a) Not be expected to occur regularly or frequently within several years Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria. b) Not typical of the normal activities or risks inherent in the normal operations of the entity Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c) Primarily out of the control of owners or management Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

2020 Ruling 2020-0838951R3 F- Post-mortem Pipeline-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) pipeline engaged in by beneficiaries following estate distribution and includes their previous shareholdings Background On the death of X, he and his two resident brothers (Leg1 and Leg2 – who were the legatees under his will of his shares of Holdco) were the holders of all the shares of Holdco consisting, in each case, of Class A voting common shares and Class C voting redeemable preferred shares. ...

28 September 2020 External T.I. 2019-0800551E5- Provincial Residency of a TFSA Trust-- summary under Subsection 2601(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(2) office of investment manager was PE to which securities trading income of TFSA was allocated When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control was factually exercised by the trustee – irrespective of the level of involvement of the TFSA holder in the decisions. ...