Search - 阿里拍卖 司法拍卖

CRA responded: S3-F6-C1 … paragraph… 1.71… indicates that such loss consolidation arrangements could be undertaken by parties that are related but not affiliated (as well as parties that are both related and affiliated and parties that are affiliated but not related). ...

. … [A] taxpayer’s share of partnership income from a Canadian limited partnership is required to be included in computing its income for the year for purposes of [that] definition…. ...

. … [T]he effect…is to treat a capital gain on a property to be sheltered by the capital gains exemption when there is unused capital gains exemption room in the year of the disposition regardless of whether such capital gains exemption room has been saved to cover a capital gain that could be realized on a disposition of other properties in a subsequent year. ...

. … [F]or capital gains purposes there is no upward adjustment (for the amount of the former grind to the CEC pool) to the cost or capital cost of the Class 14.1 property where such property is sold to an AL person after January 1, 2017. ...

. … Thus…Holdco is deemed to have received the dividend on the shares in the capital of Opco on December 31, 20X1. ...

" … Furthermore, during the period of time a worker in the Quebec construction industry holds an exemption issued by the Commission…the individual is not an "eligible apprentice"…. ...

CRA then stated: As an indication, where an employee is required to use the employee’s automobile, or a car provided by the employer, three or more days a week to perform the duties of employment, and uses the parking space for that purpose, we generally consider … that the parking space is used regularly for reasons related to the employee’s employment. ...

. … [A]n individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06. ...

. … [T]he U.S. tax paid by Usco on its share of the portion of the gain computed pursuant to the Code from the disposition of the Consideration Property by the Partnership that could reasonably be regarded as the gain and/or recaptured depreciation determined pursuant to the Code that was deferred on the disposition of the Rental Property by the Partnership would qualify as FAT. ...

. … [W]here an employee incurs meals expenses for travel outside the municipality or metropolitan area [of the employer's establishment] and the employee is reimbursed by the employer, this amount is not included in the calculation of employment income because this travel mainly benefits the employer. ...