Search - 阿里拍卖 司法拍卖

. … [However] section 7… will not apply to situations where an employer contributes an amount to a trust and the trust uses the funds to acquire shares through open market transactions. ...

However, recognizing an upstream loan would result in double counting because the assets acquired by the parent out of the proceeds thereof would already be counted for purposes of the tests – so that the loan’s value decreases the relevant FMV of the shares of the particular wholly-owned subsidiary. ...

. … Subject to the examination of the trust indenture, it would appear according to the two described scenarios that the interest of each of the beneficiaries is to be terminated as a consequence of a distribution of property of the trust to the beneficiary or his estate. ...

However, an analysis of all the relevant facts and documents would be required …. ...

. … [T]he NRCan Guide indicates that expenses for eligible property incorporated into a ground source heat pump system that qualifies for Class 43.2 treatment (by virtue of subparagraph (d)(i) of Class 43.1), include: The purchase and installation of heat pumps, pumps complete with controls and regulators. ...

The Directorate confirmed the TSO approach, which was to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...

2 November 2009 External T.I. 2009-0317541E5 F- Transfer to Corporations Owned by Brothers-- summary under Subparagraph 20(1)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) interest on debt assumed by Holdco to acquire non-dividend-bearing prefs of Opco was non-deductible even though commons also acquired – but amalgamation cured After a portion of the restaurant business of corporation (Corporation A) was spun off to a second corporation (Newco) in reliance on the s. 55(3)(a) exception and with the use of special voting-control shares in favour of the patriarch (A), with the two children of A (X and Y) then using interest-bearing loans to purchase most of the shares (being, in part, preferred shares) of Corporation A or Newco. ...

14 January 2010 Internal T.I. 2009-0323991I7 F- Débenture échangeable et opération à terme-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) only ½ deduction under s. 20(1)(f)(ii) for premium paid on cash-settling an exchangeable debenture under pre-2010 policy, and no s. 20(1)(f) deduction for cash settlement of forward A predecessor of the taxpayer had issued an exchangeable debenture exchangeable into share of a corporation (“Corporation 2”) of which the taxpayer was one of the shareholders. ...

To the extent that these entities are related … subsection 96(2.2)(c) would not be applicable for the purpose of reducing Canco's at-risk amount to the extent that the various borrowings have a legitimate business purpose and are not related to the acquisition of Canco's interest in USLP. ...

After noting that, in light of s. 249.1(3), this entailed a request for an amendment retroactive to the end of the previous fiscal year ending February 27, 2007, the Directorate stated: In general, a request for a change of fiscal year will be approved if it can be shown that the request is motivated solely by valid business reasons ….. ...