Search - 阿里法拍 司法拍卖
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Current CRA website
T4032-MB, Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2023
T4032-MB, Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2023 Notice to the reader Publication T4032, Payroll Deductions Tables, is available in sections for each province and territory. ...
Article Summary
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017 -- summary under Section 6
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 6 Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Partnerships Act- Section 6 Effect of s. 5 of the Partnership Act 1890 (U.K.) ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Paragraph (b)
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (b) Vertical amalgamations It is common for an “Acquisitionco” to acquire all the shares of a public company target (“Targetco”), whose shares are not delisted until after a delay, and to vertically amalgamate with it. ... (b) of the definition, the equity holders of the covered entity (Acquisitionco as the holder of Targetco shares) must receive equity of Amalco – and such equity is instead cancelled for no consideration. ...
Article Summary
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4: -- summary under Subsection 56.4(6)
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4:-- summary under Subsection 56.4(6) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(6) Paragraphs 56.4(6)(e) (arm's length employee exception) and 56.4(7)(d) ("goodwill amount" and "disposition of property" exceptions) provide that no proceeds can be received or receivable by the individual granting the RC. ...
Article Summary
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part I", CCH Tax Topics, No. 2132, 17 January 2013, p. 1 at p. 3 -- summary under Eligible Interest
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part I", CCH Tax Topics, No. 2132, 17 January 2013, p. 1 at p. 3-- summary under Eligible Interest Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(1)- Eligible Interest It is uncertain why the above definition [of eligible interest] excludes shares of a corporation where, for example, that corporation owns all of the shares in the capital stock of two or more subsidiary corporations. ...
Article Summary
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at pp. 3-4: -- summary under Subsection 56.4(12)
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at pp. 3-4:-- summary under Subsection 56.4(12) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(12) Discussions with the Department of Finance indicate that the intent of paragraph 56.4(12)(b) is to prevent a taxpayer from arguing that an amount received or receivable by that taxpayer that reasonably relates to an RC granted by another taxpayer should not be included in that taxpayer's income because paragraph 68(c) prevents the Minister from allocating any portion of the RC to them. ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Paragraph (c)
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (c) Wind-Up of Targetco into Acquisitionco A public company target (“Targetco”), whose shares are not delisted until after a delay, is acquired by “Acquisitionco” and then wound-up into it. ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Variable B
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Variable B Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(2)- Variable B Acquisition of Targetco for cash and Acquisitionco equity Where the shareholders of Targetco (which will not be delisted until some time thereafter) are to receive a combination of cash and shares of Acquisitionco, the cash component is included in Variable B of the formula in proposed s. 183.3(2) (so that it is subject to the tax) because equity of a covered entity (Targetco) is acquired in the taxation year pursuant to a reorganization transaction described in para. ...
Article Summary
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017 -- summary under Section 96
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Distinction between employee and partner/fixed distribution entitlement (5-20) [I]gnoring for the present section 2(3)(b) [the same as Partnerships Act (Ont.), s.3.3(b)], it was frequently held prior to the 1890 Act that employees who were remunerated by reference to the profits of a business were not partners therein, at least where it appeared from the agreement that no partnership was intended. ... & C. 867; Ex p. Chuck (1832) 8 Bing. 469; Gilpin v. Enderby (1824) 5 B. & A. 954. In such a case, an express term in the agreement negativing any implication of partnership may be ineffective vis-a-vis third parties, such as HMRC: see Fenston v. ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures On this page… Find out what an eligible capital expenditure is Find out what an annual allowance is Find out what a cumulative eligible capital account is Transitional rules – Undepreciated capital cost balance Transitional rules – Deemed gain immediately before January 1, 2017 Transitional rules – Dispositions of former ECP Transitional rules – Non-arm's length dispositions of former ECP As of January 1, 2017, the eligible capital property (ECP) system was replaced with the new capital cost allowance (CCA) Class 14.1 with transitional rules. ... Transitional rules – Deemed gain immediately before January 1, 2017 You may be able to include an amount in your income in a tax year that straddles January 1, 2017. ... Transitional rules – Dispositions of former ECP Receipts related to expenditures incurred before January 1, 2017, cannot result in excess recapture when applied to reduce the balance of the new CCA class. ...