Search - 阿里拍卖 司法拍卖

After indicating that s. 56(1)(a)(i) applies to any amount received by a taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, a superannuation or pension benefit even if it is in the nature of a single payment, and that “s. 56(1)(a)(i) … applies equally to benefits from a foreign pension plan that are attributable to services rendered while the individual was not a resident of Canada,” CRA stated: In accordance with Article 18(1) of the [Canada-Chile] Treaty, pensions arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in the Contracting State in which they arise. ...

. … Words and Phrases credit ...

. … Words and Phrases credit ...

Nonetheless, a Quebec general or limited partnership has many of the characteristics typically associated with legal personality such as being able or subject to suing or being sued in its own name, and having a separate patrimony – and CRA has “previously stated that the existence of a separate legal personality alone is generally not sufficient to distinguish certain foreign partnerships from Canadian partnerships.” ...

The proportion of 70% of the salary earned by the Physician could be considered to be situated on the Reserve and would therefore be exempt from tax …. ...

The Directorate indicated that FA4 appeared to have two separate businesses- a debt portfolio business, and a business of providing services to other foreign affiliates in the group – given inter alia that its services were mostly to other foreign affiliates (in contrast to the arm’s length customers of the debt portfolio business) and thus not principally services rendered to FA4’s own debt portfolio business. ...

Consequently, we remain of the view that any determination of whether section 9, paragraph 12(1)(x), or subsections 15(1), 56(2) or 246(1) of the Act apply to a particular shared-ownership arrangement involving life insurance policies and their respective premium payments can only be ascertained, on a case-by-case basis …. ...

Accordingly, an amount received by Spouse B from the Preference Shares would not constitute an “excluded amount” to Spouse B under paragraph (b) …. ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and without any election required. ...

. … To the extent that an election is made under subsection 12(2.2), the inclusion under paragraph 12(1)(x) will be reduced pursuant to subparagraph 12(1)(x)(vii). ...