Search - 阿里拍卖 司法拍卖

. … Given that it is our view that Weston should not have any effect on Rulings’ policy regarding interest rate derivatives, Rulings’ policy regarding interest rate derivatives would continue to apply and therefore the Bond Locks should be considered to be on income account. … ...

. … [I]f it were determined that such a comparative analysis supported the conclusion that a US LLC must be considered as a partnership for the purpose of application of the Act, we suggest that it would not be appropriate to adopt a classification approach to entities and foreign arrangements which could result in a different classification according to the province or territory of the residence (or permanent establishment) of the taxpayer holding an interest in the entity or the arrangement. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

CRA responded: Although … the child appears to be eligible for the disability tax credit …we cannot confirm whether the services that would be offered by a specialized educator (by following the XXXXXXXXXX program or other program) would be tutoring services supplementary to primary education pursuant to paragraph 118.2(2)(1.91) and if a medical practitioner would certify that the child requires such services because of the child’s learning difficulties or mental impairment … based on the information received. ...

The Directorate responded: [T]he penalties under subsections 162(7.01) and 162(7.02) will be calculated from the expiry of the filing deadline … where that information return is made after the extension date determined by the Minister pursuant to subsection 220(3). ... For example, a person who fails to complete 1,000 T4 Slips- Statement of Remuneration Paid and 50 T4SUM Summary of Remuneration Paid within the time prescribed … would be liable to a penalty under subsection 162(7.01) on a total of 1,050 information returns of the same type. ...

A, the Directorate stated: Paragraphs 146(9)(a) and (b) have the effect of adding to the income of an annuitant under an RRSP trust the difference between the FMV of the property acquired by the trust and the consideration given for the property acquired …. Similarly, subsection 146(10) has the effect of adding to the income of an annuitant under an RRSP trust the FMV of any property of the trust used or permitted to be used by the trust as security when the property began to be so used …. ...

The Directorate responded negatively: [T]he CRA may … reassess the particular taxation year (the taxation year in which a loss was incurred) only to the extent that the reassessment is made before the normal reassessment period for the particular taxation year expires. … The extended reassessment period under subparagraph 152(4)(b)(i) applies only to an assessment or reassessment made under subsection 152(6) of a taxation year for which, for example, a deduction under section 111 in respect of a loss incurred for a subsequent taxation year is claimed. ...

Respecting the subsequent “salary” payments, the Directorate stated: In spite of the fact that contributions of the taxpayer to the pension plans continued to accumulate for the period from Date 4 to Date 5, … the taxpayer and the employer did not have an employment relationship during that period…since [citing Schwartz] she was not required to provide services. … Thus, since… there was no [recommencement] of employment on Date 4… the amounts paid between Date 4 and Date 5 constituted the continued payment of a retiring allowance. ...

. … [T]he capital gain was realized by the Partnership sometime in 2015 and allocated to the Taxpayer at the end of 2015 when the Taxpayer was a resident in Canada. Therefore, pursuant to section 114, the income of the Partnership, including the capital gain realized by the Partnership, must be reported by the Taxpayer on the Taxpayer’s 2015 Canadian income tax return. … [W]hile addressing the importation of losses into Canada, subsection 96(8) does not prevent the recognition of gains in Canada. ...

. … [S]ubsection 104(24) provides a rule of application that alters the ordinary result…only if…an amount has first been determined to have become payable to a beneficiary. As no amount has become payable to a beneficiary pursuant to subsection 104(6), subsection 104(24) has no application. … By analogous rationale, in our view no amount may be included in computing the income for the year of a minor beneficiary under the trust pursuant to subsection 104(13) in this case. ...

. … Thus, to the extent that the annuitant acquired units of the Co-op from the trust governing his RRSP that have a nil FMV, the cost of the units to the annuitant would be deemed to be nil by virtue paragraph 69(1)(a). The excess amount paid by the annuitant to the trust governing the annuitant's RRSP would be treated as a premium, and could result in an over-contribution …. ...