Search - 2002年 抽纸品牌 质量排名

2 May 2002 Internal T.I. 2002-0132877 F- DÉDUCTIBILITÉ DES INTÉRÊTS-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money to acquire common shares generally deductible Regarding the deductibility of interest on money borrowed to acquire common or preferred shares, the Directorate stated: [I]n general and unless there are exceptional circumstances, interest on money borrowed to acquire common shares is deductible, taking into account that the potential return to the shareholder may exceed the cost of borrowing. … [I]nterest on money borrowed and used to acquire common shares may not be deductible where there is no expectation of profit from the investment. For example, in a situation where a corporation has not paid a dividend since incorporation and the facts clearly indicate that it has no intention of doing so, there may be a good argument for concluding that there is no expectation of profit …. ... However, where the dividend rate is lower than the cost of borrowing, the Agency allows the interest paid on money borrowed to acquire these shares to be deductible to the extent of the dividends included in the borrower's income from the shares in the year, grossed up in the case of an individual …. ...

2 October 2002 External T.I. 2002-0118815 F- DIABETE JUVENILE-- summary under Paragraph 118.3(1)(a.1) Summary Under Tax Topics- Income Tax Act- Section 118.3- Subsection 118.3(1)- Paragraph 118.3(1)(a.1) child with juvenile diabetes does not generate the infirm credit, including under para. ... Furthermore, although controlling blood sugar levels is important for a person with diabetes, the time spent on this activity is not … time spent administering treatment. ... That activity does not usually last an average of 14 hours a week …. ...

6 November 2002 External T.I. 2002-0132395 F- Robot Class 10 Catégorie 10-- summary under Paragraph 10(a) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10- Paragraph 10(a) cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment” – which is broadly construed) and Class 8(j) (“radiocommunication equipment”) A person carries on a business of inspecting and maintaining ventilation and sewer system ducts using 4-wheeled robots to inspect ducts. ... Consequently, it seems that … it would be necessary to allocate the cost of the robot borne by the taxpayer between depreciable property in Class 10 and depreciable property in Class 8 …. ...

6 November 2002 External T.I. 2002-0132395 F- Robot Class 10 Catégorie 10-- summary under Paragraph 8(j) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(j) cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment”) and Class 8(j) (“radiocommunication equipment” – informed by IA meaning of “radiocommunication”) A person carries on a business of inspecting and maintaining ventilation and sewer system duct using 4-wheeled robots to inspect ducts. ... Consequently, it seems that … it would be necessary to allocate the cost of the robot borne by the taxpayer between depreciable property in Class 10 and depreciable property in Class 8 …. ...

25 January 2002 External T.I. 2001-0114615 F- CONTRAT DE RENTE PRESCRITE ET FIDUCIE-- summary under Clause 304(1)(c)(iv)(B) Summary Under Tax Topics- Income Tax Regulations- Regulation 304- Subsection 304(1)- Paragraph 304(1)(c)- Subparagraph 304(1)(c)(iv)- Clause 304(1)(c)(iv)(B) requirement of fixed term where holder is a trust other than under s. 104(4)(a) In the course of a general discussion, CCRA stated: Clause 304(1)(c)(iv)(B) … has the effect of requiring that annuity payments be payable for a fixed term where the holder of the contract is a trust other than a trust described in paragraph 104(4)(a) …. ...

9 August 2002 Internal T.I. 2002-0145817 F- TAUX DE DEDUCTION- PTPE- ANNEE 2000-- summary under Paragraph 38(c) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(c) BIL realized under s. 50 at end of year (2000) so that ½ an ABIL An allowable business investment loss was recognized by an individual in an amount equal to ½ the business investment loss (BIL) realized by the individual in 2000 given that such loss arose from a deemed disposition pursuant to s. 50(1) which, therefore, was deemed to have occurred on December 31, 2000. ...

20 December 2002 External T.I. 2002-0159365 F- REMUNERATION NON MONETAIRE-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deduction or remittance obligations where all remuneration is non-monetary Regarding the applicability of source deductions to non-monetary remuneration, CCRA stated: [T]he CCRA will not require source deductions for income tax purposes if non-monetary remuneration is the only payment received by the employee, since there is then no amount from which the employer can deduct. … [T]herefore … a corporation that pays certain of its directors remuneration consisting solely of shares of the corporation would not be required to deduct source deductions on the value of this remuneration in shares. ...

14 January 2002 External T.I. 2001-0114035 F- ECHANGE D'ACTIONS ET PARAGRAPHE 9001(2)-- summary under Paragraph 9001(2)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 9001- Subsection 9001(2)- Paragraph 9001(2)(a) shares will remain prescribed shares if the corporation ceases to be a QSBC after one year CCRA stated: Paragraph 9001(2)(a) … provides that a share of the capital stock of a corporation is a prescribed property of a taxpayer if, immediately after the time at which the taxpayer acquired the share, the corporation was a qualified small business corporation, and the corporation continued to be a qualified small business corporation for one year after that time. If the corporation ceases to be a qualified small business corporation after the one-year period following the time at which the taxpayer acquired the share, we are of the view that the share will remain a prescribed property, within the meaning of subsection 9001(2) …. ...

12 April 2002 External T.I. 2002-0122495 F- PRIME PAYEE SUR OBLIGATION-- summary under Paragraph 7000(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 7000- Subsection 7000(1)- Paragraph 7000(1)(b) determination of Reg. 7000(1)(b) proportions made on a taxpayer-specific basis Regarding whether the proportions referred to in Reg. 7000(1)(b) are determined by reference to the specific taxpayer and not on all taxpayers who held the bond. CCRA stated: [T]he proportions referred to in paragraph 7000(1)(b) … should be determined, for a specific taxpayer, by considering all payments that the issuer of the obligation is required to make after that taxpayer has acquired the obligation. Consequently, a second holder of a bond will not automatically be subject to the rules in paragraph 7000(1)(b) … solely because that holder was not entitled to receive the interest payable under the bond before acquiring it from the first holder. ...

11 July 2002 External T.I. 2002-0126795 F- RESSOURCES INTERMEDIAIRES REVENU EX-- summary under Paragraph 81(1)(h) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) contributions paid to a Quebec intermediate resource have been treated as means-based assistance CCRA noted: [W]e have determined in the past that a contribution paid by an institution to a family-type resource or an intermediate resource under the A ct respecting health services and social services was usually a social assistance benefit paid to an individual under a provincially legislated program, on the basis of a means, needs and income test. In addition, where a user has been referred to a family-type resource or an intermediate resource by a "public institution" under [such] Act … part of the user’s contribution may also constitute such a benefit. This would be the case, for example, for any portion of a user's contribution that comes from the guaranteed income supplement or spouse's allowance paid in accordance with the Old Age Security Act or that comes from amounts of last-resort financial assistance paid under the [Quebec] Employment Assistance Program …. ...