Search - 阿里拍卖 司法拍卖

. … However, we are of the view that family ties may be more likely to give rise to the existence of a non-arm's length relationship between particular persons. ...

29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Paragraph 20(1)(d) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(d) capitalization of unpaid interest by way of novation constituted its payment CRA indicated that the capitalization of unpaid interest on a student loan would constitute the payment of such interest if there was a concurrent novation of the loan by way of change of debt under the governing Quebec law – but that the novated loan would be a new loan rather than qualifying as a loan made under the applicable Quebec post-secondary student assistance program. ...

After noting that “qualifying revenue" generally referenced “the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity,” CRA stated: [A] member's share of the profits of a partnership, as allocated to the member pursuant to subsection 96(1) and in accordance with the partnership agreement, is not "qualifying revenue" to the member …. ...

CRA responded: [A]s ACo and BCo are not associated in the taxation year, the two corporations would not be required to aggregate their taxable capital employed in Canada for the purpose of paragraph 125(5.1)(a) …. ...

23 January 2024 External T.I. 2023-1000021E5- Total charitable gifts for a particular year-- summary under Subsection 118.1(2.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(2.1) claims made on a FIFO basis CRA confirmed that an individual can choose (under s. 118.1(1)- "total charitable gifts" – (c)(i)(A)) not to claim a charitable donation in a particular year and carry forward the claim for up to five years, subject to the s. 118.1 limitations. ...

1 February 2001 External T.I. 2000-0049655 F- Transfert entre conjoints de crédit d'impôt-- summary under Total Cultural Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Cultural Gifts credits from gifts of cultural property can be reallocated between spouses, but s. 69 gains cannot be reallocated Regarding whether an individual who has donated cultural property could transfer the donation credit to their spouse, CCRA confirmed that a gift made by a spouse may be claimed by either spouse regardless of the name of the donor appearing on the receipt – but that gain under s. 69(1)(b)(ii) was required to be recognized only on the basis of the ownership interest in the donated property. ...

11 May 2017 External T.I. 2016-0679751E5 F- TFSA- Exempt Contribution-- summary under Paragraph 248(8)(a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(8)- Paragraph 248(8)(a) legacy made by executor exercising discretion conferred under will occurred because of death The definition of “survivor payment” in s. 207.01(1)- exempt contribution – para. ...

This would not satisfy CCRA’s “concern … to ensure that the total value of the consideration received in shares (redemption value) and non-shares is equal to the fair market value of the property disposed of pursuant to subsection 85(1).” ...

Consequently … the attribution rules set out in section 74.1 of the Act could apply to income from a life insurance policy that is a substitute for the property loaned. ...

. … [A]s noted in the Explanatory Notes of the Department of Finance, section 84.1 is “an anti-avoidance rule designed to prevent the removal of taxable corporate surplus as a tax-free return of capital through a non-arm’s length transfer of shares by an individual resident in Canada to a corporation.” A scheme that allows an individual to strip a private corporation of its surpluses through a reorganization that would result in indirect holding of its shares through a partnership appears to circumvent the application of section 84.1. … [A]llowing a taxpayer, other than a corporation, to carry out a reorganization allowing a change in ownership of the shares of a private corporation by transferring them to a partnership in order to subsequently dispose of the partnership's interest to another corporation with which the taxpayer does not deal at arm's length could be a stratagem to strip the surplus of a corporation and circumvent section 84.1. ...