Search - 阿里拍卖 司法拍卖

. … The CRA's longstanding position is instead to reduce the safe income on hand by every dollar of expenses that contributed to the loss sustained by the corporation on the grounds that such income is no longer on hand to contribute to the unrealized capital gain on a share. ...

After referencing the position in IT-160R3, para. 9, that a controlling shareholder generally will be considered to have received a benefit qua shareholder where “there is extensive use of the aircraft for personal purposes by the shareholder-employee or … relatives or friends,” CRA stated: [T]he benefit arising from the person's use of the aircraft by the corporation's founder-president should be based on the price of a regular first class ticket for a scheduled flight to the same destination, as the founder-president received the benefit as an employee of the corporation. ...

. … In the case where each of the co-owners has the exclusive right to live in his or her own unit, the value of their undivided share must take into account at the same time the exercise by each of them of the exclusive use and enjoyment of their unit, which necessarily includes the right to the use of the common parts of the building, and the prohibition on the use of the unit occupied by the other co-owner. ...

[T]he deductions [under s. 153(1)(j)] are … made from the lump sum payment and designated as being for the account of the person receiving the amount, being the RRSP annuitant. ...

. … [W]here a trustee or an insurance company pays benefits to an employee from a wage-loss replacement plan over which the employer does not exercise control, or where the employer does not determine eligibility for benefits, the trustee or insurance company is required to report the benefit amounts on a T4A information slip. ...

. … On the other hand... a meal allowance to which an employee is entitled after working a certain minimum amount of overtime to be taxable if the payment to the employee is not truly related to whether or not the employee actually takes a meal. ...

1 April 2010 Internal T.I. 2009-0352611I7 F- Redressement après le délai de prescription-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) statement of incorrect income amount for spouse for s. 118(1)(a) credit purposes is a misrepresentation – but CRA must establish that prudent person would not have so erred Where a taxpayer claimed the married or common-law partnership tax credit (the "Tax Credit") and, after the taxpayer’s spouse was assessed beyond the normal reassessment period to add unreported income, can CRA also reassess the taxpayer beyond the normal reassessment period? ...

. … The CRA has already concluded in some of these types of cases that avoidance transactions are caught by subsection 245(4) and that the general anti-avoidance rule applies. ...

After noting that in the absence of an s. 89(11) election, Corporation B became a CCPC on June 1, 20-A, CRA stated: [As] Corporation B did not make an election under subsection 89(11) to not be a CCPC until November 14, 20-B … the exception in paragraph (d) of the definition of CCPC in subsection 125(7) could only apply to Corporation B for the taxation year beginning on June 1, 20-A and ending on May 14, 20-B, and thereafter... ...

In general … the exception in paragraph 55(3)(a) would appear to apply in respect of deemed dividends resulting from the cross-redemptions between Holdco Inc. and Holdco 2 Inc. ...