Search - 阿里拍卖 司法拍卖

Base erosion – services (ss.95(2)(b)(ii)) Question Notes from Presentation CRA Response Written Response Q9. 95(6)(b) – post Lehigh Question Notes from Presentation CRA Response Written Response Q10. ... See summary under s. 248(1) – derivative forward agreement. Written Response 2 December 2014 CTF Conference Q. 1, 2014-0546701C6 Q1. ...

Email this Content 2022 Alberta CPA Roundtable Q.1- Dealing with CRA on Assessments and Reassessments Q.1(a) CRA Comments Q.1(b) CRA Comments Q.1(c) CRA Comments Q.1(d) & (c) CRA Comments 2. ... Q.1(d) & (c) d) What is the best approach to resolve these issues? ... Response d) & e): CRA Comments Providing all the supporting documentation and clearly indicating the fields to adjust could help prevent issues with the requested reassessment. ...

Q4 Voluntary Disclosure – “One Year” Rule Etc. Facts/Background A Co., a GST non-registrant, purchases a residential complex in January 2007. ... In that case, the assessments were issued on letterhead from Revenue Canada – Taxation rather than the Department of National Revenue and had the printed signature of a person who was no longer the Deputy Minister. ... The Notices of Reassessment issued since April 1, 2007 are made up of a “Results” page and one or more “Summary of (Re) Assessment “ pages. ...

Official Response 15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Q.2- Withholding if swap mismatches A Canadian resident taxpayer (Canco) enters into a Swap Agreement (Swap Agreement) with a non-arm’s length non-resident company (NRco). ... This is where the wage subsidy – we’ll say $10 in this case – would be taken into account. ... Subpara (ii) describes other circumstances where distributions can be traced to the initial investment – in this case, the shares of FA1. ...

D & D Livestock What is the CRA's position regarding [D & D Livestock] which allowed a taxpayer to take into account twice the amount of the "safe income" in the context of subsection 55(2) of the ITA? ... The advance rulings consultation process started slowly – only 6 or 7 in the first 9 months. In the last 3 months there were 21 files – 17 of them concluded. In 9 of them the taxpayers were told “no way.” ...

Although s. 107(2) is not applicable to this situation, consideration could be given to whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could apply to allow the property to be transferred on a tax-deferred basis. ... In other words, whether or not a s. 256(9) election is made, the "?" ... Alternatively, if you do elect out, you will not get a roll-in on the transfer in – it will be at fair market value, and the trust will not have a deemed disposition or year-end on the death of the settlor. ...

An overview of the relevant facts can be illustrated as follows: Beginning End ──────────────────────────────────── ──────────────────────────────────── ┌───────┐ ┌────────┐ ┌────────┐ ┌────────┐ ┌────────┐ ┌────────┐ │Partner│ │Partner │ │Partner │ │ │ │Partner │ │Partner │ │ A │ │ B │ │ C │ │ A │ │ B │ │ C │ └───┬───┘ └───┬────┘ └───┬────┘ └────────┘ └────┬───┘ └───┬────┘ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ └────┬─────┴───────┬──┘ ┌─────┴─────────┤ │Partnership I│ │Partnership II │ │ Assets │ │ Assets │ └─────────────┘ └───────────────┘ We assume that any wind-up of Partnership I would be effected on a tax-deferred basis for the purposes of the Income Tax Act. ... Q.22- Section 156 Election Can Canco #1 and Canco #2 enter into the section 156 election under the following corporate structure: ┌─────────┐ │ │ │ U.S. │ ┌────┴─────────┴────┐ │ │ 100%│ │100% │ │ ┌────┴────┐ ┌────┴────┐ │ │ │ │ │ U.S. #1 │ │ U.S. #2 │ └────┬────┘ └────┬────┘ │ │ 100%│ │100% │ │ ┌────┴────┐ ┌────┴────┐ │ │ │ │ │Canco #1 │ │Canco #2 │ └─────────┘ └─────────┘ Assume that: (i)Canco #1 and Canco #2 are corporations resident in Canada and are registered for GST; (ii)U.S., U.S. #1 and U.S. #2 are non-residents of Canada and are not registered for GST. ... If so, how can this position be reconciled with the Carlson & Associates Advertising Ltd., [1998] G.S.T.C. 25 decision? ...

Q.2b – CRA guidance on PPT Lori Carruthers: Given that each situation is likely to be unique, we again recommend Advance Income Tax Ruling as the best source of certainty. ... Q.2c – Expedited rulings Lori Carruthers: No, we will not commit to an expedited basis, although we are sensitive to the need for all taxpayers to receive a response to a ruling request as quickly as possible, and we are working towards that. ... CRA will consider a request for relief in the form of extensions and waivers of penalties on a case-by-case basis – although I would expect that the Minister will require more than “they just shortened the deadline from 15 to six months!” ...

Part 1 – Child group indirectly owns purchaser corporation “Can the child group own the purchaser corporation through on ore more holding companies owned by them?” ... Part 2 – Purchaser corporation held beneficially by child group “Can shares of the purchaser corporation be held by a trust under which the only beneficiaries are members of the child group?” ... Part 3 – Child group are trustees “Can shares of a purchaser corporation be held by a trust if the trustees are all members of the child group and the parents are not beneficiaries?” ...

Of course, disputes will still happen – just look at the Trump tax-reforms in the US. ... It’s the same thing with the litigators – it’s something that auditor teams can have on request. ... Michael O’Connor – Does that include drafts of working papers? Gord Parr – Generally the final documents will suffice. ...