Search - 阿里拍卖 司法拍卖

CRA stated: In the case of a corporation, some of whose activities are employee lease-out services, that is, that the employee's services are retained by that corporation but the employee's duties are performed, in whole or in part, for another organization …, it is necessary to determine whether the corporation is carrying on a separate business … because … the employment income of an Indian from each of the businesses of such a corporation is … a separate property for the purposes of … section 87 …. ...

. … Finally … Ahmad … held that pre-judgment interest was not taxable because no amount was owed to the taxpayer before the judgment was rendered. ...

The Directorate stated: # 2007-022925 and # 2004-0107761E5 … stat[ed] that in situations similar to those of Ms. ...

XXIV(2)(a) is expressly “subject to the provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada,” and stated: [T]his means that a Canadian resident is subject to the limitations on claiming a foreign tax credit found in the Canadian legislation, and more specifically in section 126, including a timing restriction on when a foreign tax credit may be claimed (see … 2015-0601781E5 ….) ... XIII(7) is not available … and the year of the Deemed Disposition … does not occur in the same year [as] … for U.S. income tax purposes … the Trust may not obtain a foreign tax credit in Canada for the U.S. taxes paid in a year subsequent to the year of the Deemed Disposition (assuming the Trust has insufficient income from other sources in the U.S. in the year the U.S. Property is considered by U.S. income tax laws to have been disposed) …. ...

The Directorate stated: [B]ased on the terms of the Payment Agreements … Canco agrees to make advanced payments to NR that are set off or deducted from the amount due by Canco to NR required under the Initial Contract. ... As such, the nature of the payments is different from [those] … in … 2008-29716 …. ... Accordingly … the advance payments made by Canco to NR under the Payment Agreements are subject to the withholding requirements of section 105 …. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...

For the latter amount to be accepted, it must be reasonable in amount, as to which the Directorate stated: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

We consider those benefits to be "social assistance benefits" …. … The benefits are not solely for the benefit of an Indian resident on a reserve and are therefore not personal property of an Indian resident on a reserve and are therefore not exempt from taxation under [the Indian Act]. ...

16 December 2019 Internal T.I. 2019-0816101I7- Loans from LTD Partnerships to LTD Partner-- summary under Paragraph 96(2.2)(c) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2)- Paragraph 96(2.2)(c) validity of loan by Ontario LP to limited partner turns on Ontario law When asked whether loans by an Ontario limited partnerships to limited partners would be treated as a loan for purposes of s. 96(2.2)(c), the Directorate indicated that: The reference in s. 96(2.2)(c) to an “amount owing” by a partner to a partnership does not deem partner debts to be valid, but instead merely “suggests that the legislator believed that at least in certain jurisdictions, there could be a debtor and creditor relationship between a limited partner (debtor) and a limited partnership (creditor)” – for instance s. 60(1) of the Partnership Act (B.C.) ... Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act providing: “A limited partner may loan money to and transact other business with the limited partnership ….”) – but indicated that the doubts expressed in 2016-0637341E5 as to whether it was possible under the civil law for a limited partnership to make loans to a limited partner were not meant to apply to Ontario limited partnerships. ...

The Directorate concluded: [W]here the installation of such equipment is provided for in the plans and specifications for the construction of a building and the installation is carried out at various stages of the building's construction … it would be difficult to conclude, for this type of contract, that the Taxpayer is not a subcontractor engaged in the construction of a building since those activities are part of the building's construction process. On the other hand … the manufacture and installation of kitchen equipment in buildings already constructed or inside various means of transportation do not constitute activities relating to the construction of a building …. … [T]he Taxpayer may avail itself of the progress method set out in Interpretation Bulletin IT-92R2, provided that title to the construction vests in the Taxpayer's client or in the owner of the building as the work progresses and, furthermore, that the manufacture and installation of the particular equipment are provided for in the plans and specifications for the construction of a building. ...