Search - 阿里拍卖 司法拍卖

After finding that the time of the forgiveness was at the time of the court approval of the proposal, CRA indicated that the resulting tax applicable to the income under s. 80(13) did not arise until that time, stating: … Opco's debt attributable to the amount of income tax payable arising from the application of I.T.A. subsection 80(13) is not a "provable claim" for the purposes of a proposal, as the tax liability of the debtor corporation arising from the application of subsection 80(13) is generally not determinable until after the proposal is approved by a court. ...

Regarding the latter, it stated: [A] reasonable one-time guarantee fee … paid respecting the term of the loan would generally be deductible pursuant to paragraph 20(1)(e), taking into account the application of subsection 18(9), if applicable. ...

CRA indicated that, no, its position remained that premiums payable in respect of a CII policy assigned as security for a loan of the corporation cannot be deducted in computing its income from a business or property pursuant to s. 18(1)(b) since they constitute capital expenditures, and that they are not deductible pursuant to s. 20(1)(e), (e.1) or (e.2) – and that this position would not change if the CII policy was assigned to the lender by naming the lender as the beneficiary of the policy or by way of a movable hypothec. ...

CRA characterized the arrangement as one under which the client invested $21,000 in the GIC, of which $20.842.50 came from the client’s own funds and $157.50 came from the commission received by the broker from the bank which it applied to the payment of the balance of the client’s GIC – so that the cost of the GIC to the Client was $21,000. ...

However, CRA instead characterized the arrangement as one under which the client invested $21,000 in the GIC, of which $20.842.50 came from the client’s own funds and $157.50 came from the commission received by the broker from the bank which it applied to the payment of the balance of the client’s GIC – so that the cost of the GIC to the client was $21,000. ...

. … For CEWS purposes, when the payment is added by the employer, which is an eligible entity, to the basic salary or wages included in each paycheck of an eligible employee, we will consider that the eligible entity has paid the payment to an eligible employee in respect of the same week as the related salary or wages are paid. ...

. … [T]he employees' travel is therefore not for the purpose of travelling away from the municipality and, where applicable, the metropolitan area where the employer's establishment was located. ...

CRA responded: [A]s there is no income that is received (directly or indirectly, in any manner whatever) from the provision of services or property between ACo and BCo, there would not be any income that would be as described in subparagraph (a)(i) of the SCI definition …. ...

CRA then stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

Although the Income Tax Rulings program is there to provide advance comfort on the tax consequences of a transaction, as noted in IC70-6R12, CRA will not confirm the fair market value of a property, and the Rulings program is not in a position to verify the facts provided – and there are also timing considerations. ...