Search - 阿里拍卖 司法拍卖

. … [T]he tax-free amount available to the shareholders of a corporation (including a corporate 149(1)(n) entity), through the CDA, will generally be limited to one half of the capital gain. However, should it lose its exempt status, it also would lose its CDA under s. 89(1.2) – and the timing of the capital gains arising to it under the s. 149(10) disposition of its property would preclude those gains from being added to the available amount of its CDA. ...

. … [P]ayments such as reimbursements of tuition, bursaries or scholarships paid by an employer to help individuals continue their education can be part of a "program" …. ...

5 January 2011 Internal T.I. 2010-0386951I7 F- Résident temporaire- PFCE-- summary under Eligible Individual Summary Under Tax Topics- Income Tax Act- Section 122.6- Eligible Individual tax residency is referred to in (a) but not in (e)(ii) When asked to comment on s, 122.6(e)(ii) of the definition of "eligible individual," the Directorate stated: [T]he condition in paragraph (a) means that the individual must live with the dependant … [and that] in paragraph (c) means that the individual must be a resident of Canada for the purposes of the Act. … [T]he condition in subparagraph 122.6(e)(ii) does not refer to residency in Canada for the purposes of the Act. ...

23 June 2010 Internal T.I. 2010-0368161I7 F- 84.1-- summary under Paragraph 84.1(2.2)(b) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.2)- Paragraph 84.1(2.2)(b) s. 84.1(2.2)(b) group can include a non-voting shareholder Three individuals (A, B, and C) each held 1/3 of the shares of Holdco, and Holdco and another individual, D, each held ½ of the shares of Opco. ... The Directorate responded: [S]ince paragraph 84.1(2.2)(b) … refers only to "shares", a person who holds only non-voting shares and another person who holds voting shares may indeed form a group of persons within the meaning of paragraph 84.1(2.2)(b) and for the purposes of applying paragraph 84.1(2)(b). ...

In responding “yes,” the Directorate stated: According to … IT-113R4, paragraph 12, pursuant to the definitions of "employee" and "office" in subsection 248(1), corporate directors are considered to be employees. ... The Queen, it was established that for the purposes of the Act, a director of a corporation is an "employee" of the corporation even though the director does not receive remuneration for the director’s services and does not provide services in the same manner as an ordinary employee. … ...

18 December 2006 Internal T.I. 2006-0208611I7 F- Indemnités pour lésions professionnelles-- summary under Subsection 232(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 232- Subsection 232(4) Reg. 232(4) exclusions are broader than those listed After indicating that the s. 56(1)(v) inclusion and s. 110(1)(f)(ii) deduction could apply to amounts paid by a bank pursuant to the Canada Labour Code to Ontario employees in amounts not in excess of the amounts that would have been payable pursuant to Ontario's Workplace Safety and Insurance Act scales, the Directorate stated: Pursuant to [Reg.] 232(1) …, every person who pays an amount in respect of compensation described in subparagraph 110(1)(f)(ii) of the Act shall make an information return in prescribed form in respect of that payment. That prescribed form is the T5007 slip …. Also excluded from the T5007 are amounts coming within subsection 232(4) of the ITR, such as interest payments, compensation for non-financial loss, payments under a labour market reintegration program, medical expenses and lump-sum payments to survivors. ...

The Directorate went on to state: The surplus of CFA could conceivably be adjusted where CFA’s “earnings” are computed pursuant to subparagraph (a)(i) or (a)(ii) of the definition of “earnings” under [Reg.] 5907(1) … and the relevant foreign tax law makes its own transfer pricing adjustment, whether by way of a corresponding adjustment or otherwise. …[C]onsideration would have to be given to whether subsection 5907(2) … could reverse that foreign tax law adjustment.... ...

24 October 2017 Internal T.I. 2017-0719531I7- Section 22 election and carrying on a business-- summary under Paragraph 87(2)(g) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(g) failure of s. 87()2)(g) to deem continuity for s. 22 purposes not fatal Immediately after its formation, Amalco dropped the business of a predecessor down to a partnership under s. 97(2) – except that it used the s. 22 election for the transferred trade receivables. The Directorate found that as a technical matter the s. 22 election was not available – effectively because s. 87(2)(g), which deemed Amalco to be a continuation of the predecessor for purposes of the ss. 20(1)(l) and (p) reserve provisions, did not go further to deem the Amalco receivables to have been includible in its income. ...

Since the premium at issuance is used to adjust the overall yield to reflect the prevailing market rate for similar securities at that time … this fact is an explicit indication that the interest rate on the loan exceeds a reasonable amount as required by virtue of paragraph 20(1)(c) …. ...

. … In this regard, section 122.3 does not contain any indication or restriction as to the contracting party to such a contract. Consequently, the fact that the contract is concluded with a person related to the specified employer does not have the effect of disqualifying the latter's employees from the OETC …. ...