Search - 阿里拍卖 司法拍卖

If in the light of the damages to the building and the scale of the work to be effected it turns out that a new property is acquired by the taxpayer, section 44 can apply …. ...

CRA responded: [W]here one or more written agreements provide for the acquisition of a house by way of legacy and gift, the CRA is generally of the view that it is a valid acquisition for the purposes of the definition of "regular eligible amount ". ...

. … As specified in IT-147R3, it is not necessary for the manufacturer or processor of the goods to be the seller. ...

27 March 2013 External T.I. 2012-0449661E5 F- Subparagraph 53(2)(c) ITA-- summary under Paragraph 53(2)(c) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(c) effect of ss. 40(3.4) and 112(3.1) on partnership ACB where dividends paid to partnership before share disposition was currently under audit In response to a query as to “the effect of the application of subsections 40(3.4) and 112(3.1) on the calculation of the adjusted cost base of an interest in a partnership … where the partnership disposed of shares of a corporation at a loss to an affiliated corporation” and “in the years prior to the disposition, the corporation whose shares were disposed of paid dividends on its shares to the partnership,” CRA indicated that this appeared to be a situation currently under audit, so that it could not comment. ...

CRA stated: Paragraph (g.1) of the definition "Canadian exploration expense" in subsection 66.1(6) … includes CRCE. ...

. … However, [as] it is a question of fact whether the mutual company in the other situations [presented] was set up for the purpose of directly holding shares of an insurance corporation…we would be prepared to review all the transactions surrounding the situations you described in a request for an advance ruling. ...

26 February 2014 External T.I. 2013-0510921E5 F- Remboursement de frais médicaux à un employé-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose no need to demonstrate income production In providing a general response to the question as to whether in computing an employer could deduct, in computing its business income, amounts paid to an employee as a reimbursement for medical expenses incurred by the employee prior to implementing a health service plan, CRA stated (TaxInterpretations translation): Under the expression "... for the purpose of gaining or producing... ...

CRA responded: [P]aragraph 402(4)(c) … would apply to calculate the distribution of gross revenues for a year attributable to a permanent establishment in a province without regard to the fact that the sale was negotiated by a person assigned to the permanent establishment located, for example, in Province B. ...

. … …This is consistent with the June 6, 2012 comfort letter from the Department of Finance…[which] confirmed that the amendment was not intended to accommodate estate freeze transactions. ...

. … ...