Search - 阿里拍卖 司法拍卖

., someone who would not receive any benefits from the municipality as employment or business income) would references the situation where any consideration paid “does not adequately reflect the amount of work performed nor the quality of the services provided (whereas “where the amount of remuneration paid … is sufficient to influence their involvement or participation, it is very likely that the remuneration is taxable as employment income or income from a business”). ...

29 July 2009 External T.I. 2009-0314611E5 F- Résidence pour membres du clergé à la retraite-- summary under Paragraph 8(1)(c) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(c) provision of manse to retired Minister is not taxable employment benefit – so that no s. 8(1)(c) deduction Regarding the purchase by the Church of a residence for its retired pastors and missionaries, CRA stated: Under [the function] test, the person must perform one of the following functions to be eligible for the deduction under paragraph 8(1)(c): is in charge of or ministering to a diocese, parish or congregation; is engaged exclusively in full-time administrative service by appointment of a religious order or religious denomination …[T]he provision of housing to retired pastors and/or missionaries who no longer earn income from church office or employment will generally not result in a taxable benefit to be included in computing their income. ...

With respect to the replacement and lowering of windows with sliding openings, such expenditures could potentially qualify … if the requirements set forth above are satisfied. ...

. … [T]he repairs provided in the example are generally of an enduring nature and are integral to the dwelling and could be eligible for the HRTC if they are not annual, recurring or routine repairs or maintenance. ...

. … [T]he repairs provided in the example are generally of an enduring nature and are integral to the dwelling and could be eligible for the HRTC if they are not annual, recurring or routine repairs or maintenance. ...

11 March 2010 External T.I. 2009-0345481E5 F- Allocations versées administrateurs bénévoles-- summary under Office Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Office definition of a “volunteer” (who is excluded from the holder of an “office”) Before finding that allowances and travel reimbursements paid by an NPO to volunteer directors were generally non-taxable, CRA stated that although “a director is generally considered to hold office, this is not the case for a director who works for a company solely on a voluntary basis,” which references the situation where “individuals who work on a volunteer basis receive no remuneration or at most minimal remuneration for services rendered on a volunteer basis” – with remuneration considered minimal where the remuneration paid to the individual is “significantly less than that which would have been paid to an employee or self-employed person rendering similar services,” so that “it is unlikely that minimal remuneration is sufficient to secure the volunteer's services.” ...

7 November 2001 External T.I. 2000-0038195- Indefeasible Vesting of Interest in Trust-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) indefeasible vesting but no disposition where sole beneficiary Respecting the application of the 21-year deemed disposition rule where a trust has one beneficiary that is neither the settlor nor the settlor's spouse, CRA stated: Specifically excluded [from the rule] is a trust all interests in which have vested indefeasibly at the time the rule would apply, other than those trusts listed in subparagraphs (g)(i) to (vi) …. ...

9 August 2017 External T.I. 2017-0709351E5- Interaction between subsections 98(1) and 116(5)-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) gain from negative partnership interest ACB not subject to s. 116(5) Where a partnership has ceased to exist, any negative adjusted cost base to a taxpayer (including a non-resident) of its partnership interest at the end of the fiscal period is deemed to be a capital gain from a disposition of its interest in the partnership – but its partnership interest is not deemed to be disposed of to the partnership (cf. s. 84(9).) ...

After noting that such amounts likely would not be taxable to the recipients if they were provided “on a one-off or very irregular basis … as this activity does not sufficiently occupy the taxpayer's time and effort,” CRA stated: [N]o information slip is required to be made where the amount paid to a taxpayer is not taxable. ...

Furthermore, we do not intend to propose to the Department of Finance that the conditions for making an election by virtue of subsection 184(3) be changed, since there is a valid legislative alternative …. ...