Search - 阿里拍卖 司法拍卖

" This could be the case given that the payment of the dividends may have fully accessed any available exempt surplus of CCo, whereas if there instead had been a sale of CCo shares to NR1 at a gain followed by a s. 93(1) election, the amount of exempt surplus which was accessed under the operation of Regs. 5902(1) and 5901 could be more limited – which would result in pre-acquisition surplus dividends grinding basis under s. 92(2) which, in turn, would result in a taxable capital gain which was foreign accrual property income. ...

. … If it is instead established on the facts that the taxpayer did not ordinarily reside at Location 2 before ordinarily residing at Location 3…[e]xpenses related to the sale of the residence at Location 1 would be considered expenses of the move from Location 1 to Location 3…. ...

…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...

. … Above, it was noted that transactions that fall within sections 51, 86, 87 or 85.1 are carved out of a “merger” in subparagraph 40(3.5)(c)(i). ...

For the purposes of subparagraph 81(1)(h)(i), we are of the view that the children's special allowance [so] paid … is not an amount of family allowance under the LAF and the payment of such an allowance would not preclude the exemption from the social assistance benefit that would otherwise qualify pursuant to paragraph 81(1)(h). ...

The EPSP trust would use an interest-bearing loan from Employerco to fund its purchase of the matching number of Employerco shares and fund the loan interest with dividends on the shares and annual contributions from Employerco – both of which were taxable income to it but with an offsetting interest deduction, so that there would be no annual income inclusion to the participant under s. 144(3). ...

“Moreover, any prior statements to the effect that a particular incentive plan does not give rise to a SDA because it is future-oriented at time of grant should not be construed as a categorical statement that all future-oriented plans fall outside the scope of the SDA rules.” “… [A]n incentive plan can be a SDA before the final value of the units has been determined at the occurrence of the triggering event. ...

. … [T]he filing of the subsection 82(3) election is not inconsistent with the TOSI policy, and this view is not impacted by the ability to late file or amend a subsection 82(3) election. ...

“[C]onsistent with the previously noted longstanding position of the CRA that subsection 220(2.1) cannot override subsection 220(3.2),” it is “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in section 600 of the Regulations” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

IX(3) of the Canada-Barbados Treaty apply to preclude Canada from assessing Canco to increase its profits pursuant to ITA s. 247(2) (a “Primary Adjustment”) given that the five year period had passed – but also being mindful that BarbadosCo was an enterprise referred to in Art. ...