Search - 阿里拍卖 司法拍卖

. … [Respecting] the last condition…provided that at the time FA Finco receives the amount of penalty, FA Holdco continues to hold the shares of FA Opco that constitute a source of income for FA Holdco, the fourth condition of Clause D would be satisfied. ...

. … …[T]his type of deduction would not be covered by any of the exceptions set out in the definition of "annuities" in Article 18, paragraph 5….. ...

XXIX(5) of the Canada-France Convention: [or as non-business income tax for the purposes of section 126]: CSG ("contribution sociale généralisée" ["general social contribution"]) CRDS ("contribution pour le remboursement de la dette sociale " [contribution for the repayment of the social debt]) Sécurité sociale vieillesse [old age social security] (retirement) Pole emploi (similar, in your opinion, to Employment Insurance) Retraite complémentaire [supplementary pension] (according to you, mandatory)? ...

The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

. … [Y]our mother did not ordinarily inhabit the residence during the years XXXXXXXXXX to XXXXXXXXXX. ...

Specific clauses in the trust deed providing that certain types of payments will constitute income to the trust are acceptable- the “fact that the trust deed provides that certain types of payments will constitute income does not, in and of itself, determine whether the conditions of subsection 104(18) … are satisfied, including the condition referred to in subsection 104(18)(c).” ...

However … under subsection 256(2), Aco could elect in prescribed form for the 2004 taxation year not to be associated with either Bco or Cco. ...

CRA responded: [S]ubsection 256(2) would not apply in the particular taxation year … because Aco and Bco would be associated with each other in the particular year but for subsection 256(2). ...

The amount of interest on the "overpayment" would be calculated at the prescribed rate … for the period from the latest of the days referred to in paragraphs 164(3)(a) to (e), taking into account paragraph 164(5)(d), to the day on which the amount is refunded or applied. ...

(a)(i)(B)(I) of that definition indicates that such income is excluded from being specified corporate income for such SBD purposes if “it is not the case that all or substantially all of [Opco B]’s income for the year from an active business is from the provision of services or property to … persons (other than the private corporation) with which [Opco B] deals at arm's length.” ...