Search - 阿里拍卖 司法拍卖

Had this been the case, the $1,000 exemption would lose all of its meaning as it only applies to taxable income. … … [P]rovincial laws … such as legislation on labour standards or on occupational health and safety … [define] "volunteer firefighters" …. ... This approach allows some light to be shed on the meanings provincial government authorities accord to the expression as well as municipal or other public administrations. … [M]unicipalities and other public authorities are better able to determine the status of their employees. Paragraph 81(4)(b) states that this responsibility clearly falls on the shoulders of the municipality or public authority. … [On] an audit …[it] could be asked to … justif[y] its decision to grant … the exemption …. ...

Jan 1 1.50 Deposit US$100K from Cdn. bank account None – not a tax transaction Feb 1 1.40 Withdraw US$20K to buy shares Capital loss based on the excess of value of US$20K on Jan 1 compared to Feb 1 June 1 1.35 Deposit US$100 of dividends Dividend recognized based on 1.35 rate at dividend payment July 1 1.30 Deposit $20K of share sale proceeds Capital loss from disposition of $2,000 (their ACB of $28,000 (US$20,000 x 1.40) over the proceeds of $26,000 (US$20,000 x 1.30) Sep 30 1.20 Transfer US$50K to Cdn bank account The average exchange rate is 1.46, being the ratio of the total of each of the transactions in the bank account expressed in Cdn dollars [(150,000- 30,000 + 135 + 26,000) = 146,135] to the balance of that account in USD [(100,000- 20,000 + 100 + 20,000) = 100,100]. ...

CRA stated: The taxpayer's administrative policy for all officers and directors to reimburse the cost of a business class airline ticket in certain circumstances primarily benefits the employer. … [B]usiness class air travel may allow the employer to get better performance from the employee. Consequently … the reimbursement … does not constitute a taxable benefit …. … [T]he reimbursement of the spouse's ticket is made primarily for the benefit of the employee and … the latter derives an economic advantage from it. ... Thus … the reimbursement … is a benefit to be included in the employee's income under paragraph 6(1)(a). ...

. … [O]ur position that subsections 15(2) and (2.1) may apply to situations involving partnerships is consistent with the tax policy underlying the application of those subsections. … … CRA … appealed the Tax Court of Canada's decision. ...

CRA indicated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. ... The CRA will in general consider that [subpara. 2(c)] … is satisfied even if a particular vendor is not directly involved in the negotiations for the sale of shares, when [the other conditions are satisfied]. … … T5013 forms … do … not constitute a return of income for the purpose of [subpara. 2(e)] …. ... Therefore, neither a partnership nor the partners of a partnership in situations such as described above may use the cost recovery method …. ...

CRA responded: [A]n employer of a taxpayer makes contributions to a life insurance company that fall within the definition of RCA, the life insurance company is a custodian as [so] defined …. … [H]owever … a payment made to acquire an interest in a life insurance policy is not a contribution within the definition of RCA. ...

31 August 2005 External T.I. 2005-0114421E5 F- Frais de garde d'enfants-- summary under Child Care Expense Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(3)- Child Care Expense fees for breach of contract can qualify but not educational fees CRA commented on whether the following categories of expenses incurred by parents at a childcare centre qualified as child care expense: fees paid for child care services yes additional fees paid for child care services generally yes – “fees for additional child care (where the parent picks up the child after official daycare hours) are child care expenses … provided they satisfy the other requirements of that section” outings outside the daycare no – “the purpose of those activities is not to look after the children in order to protect them and thus enable the parents to earn employment income … [but instead] is to ensure the development of the children's physical, social and artistic skills” classes and activities given at the daycare; no – “the primary purpose of those courses and activities is not to provide childcare but rather to promote the cultural, physical and artistic development of the children.” fees incurred for breach of contract generally, yes – “ 2003-0183697 … [indicated] that the phrase ‘an expense incurred...for the purpose of providing… child care services’ found in subsection 63(3) was broad enough to include expenses incurred for the breach of a contract. This conclusion is valid as long as these costs are the result of an undertaking required of the parents in order for the child care to be provided.” interest charges paid by parents who pay their bills late no – these are not “charges that are … paid to provide childcare but rather to compensate the childcare centre when a parent fails to make a payment by the agreed date” annual dues for parents wishing to be on daycare's Board no fees for sunscreen and insect repellent yes ...

CRA responded: [S]subparagraph 12(1)(x)(iii) does not apply because it … was not given as an inducement to the taxpayer or the trust to undertake certain activities. … Hudson Bay Mining and Smelting … [found] that paragraph 12(1)(x) was not applicable to the amount received by the taxpayer because the taxpayer was not the one who made or incurred the expenditure …. [S]ubparagraph 12(1)(x)(iv) does not apply because it was the trust that incurred or made the Part XII.4 tax expenditure in respect of which the credit was received, not Corporation A. … … This interpretation of paragraph 12(1)(x) … appears to be consistent with … [the] Explanatory Notes ...

A under subsection 74.2(1) …. By virtue of paragraph 40(3.6)(b), the amount of the Denied Loss … could, however, be added to … the ACB, to Mr. B, of each of the common shares of the capital stock of Opco that is owned by him immediately following the disposition …. … [A subsequent] taxable capital gain or an allowable capital loss [realized by Mr. B] on the disposition of a common share … of Opco … would not be realized or sustained by Mr. ...

In accordance with [Reg.] 4901(1) … a prescribed investment for a registered investment … is a qualified investment for … a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in … [ss.] 146(1), 146.3(1) and section 204 … [and Reg.] 4900 …. ... In addition [see] paragraph 21 of … IT-320R3 …. ...