Search - 阿里拍卖 司法拍卖

After finding that s. 115(2)(c) did not apply to deem the employment after the departure to be exercised in Canada, CRA stated: Consequently … if the non-resident person does not perform any of the employee’s employment duties in Canada, there would be no withholding tax with respect to the federal tax. ...

(c)(i) of the definition of "qualified small business corporation share," CRA stated: [P]ursuant to subparagraph 110.6(1)(c)(i) of the definition of QSBC, [CRA] is of the view that the phrase "attributable to assets used principally in an active business carried on … by the corporation" should be interpreted to refer to the fair market value of assets owned by the corporation. ...

. … [T]he term transport business does not include a transportation service that is incidental, where the services offered are offered as part of a whole. ...

8 November 2006 External T.I. 2006-0176171E5 F- Revente d'un bien amortissable- alinéa 13(7)e)-- summary under Subparagraph 39(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(b)- Subparagraph 39(1)(b)(i) capital loss denied on sale of building – proceeds reflected in UCC reduction Corporation A sold a building with a cost of $3,800,000 to an associated corporation (Corporation B) for its FMV of $4,200,000, so that s. 13(7)(e) reduced its cost to Corporation B to $4,000,000. ...

As a result, any gain accrued on the entire property would have been recognized at that time – but such gain would have been offset by the principal residence exemption. ...

Similarly, hairdressing expenses incurred by the taxpayer are not deductible since the taxpayer incurs them in order to report for work …. ...

CRA noted that the daughter would receive the net rental income as the income beneficiary of a deemed trust under s. 248(3) (so that such income was deemed to be income from property under s. 108(5)(a)) – except that when the usufruct was extinguished, there would be a dissolution of the deemed trust to which s. 107(2) would apply, so that thereafter the bare owner would become subject to tax on the rental income. ...

CRA stated: [T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent. ...

. … [C]ompensation identified as interest (including pre-judgment interest and post-judgment interest) is taxable as interest income pursuant to paragraph 12(1)(c) if it is interest by its nature. ...

CRA stated: Generally, a person is dependent on an individual if the individual provides for the individual's basic needs or necessities on a regular and consistent basis … [so that the taxpayer] cannot claim the wholly dependent person tax credit for dependants with physical or mental disabilities. ...