Search - 2002年 抽纸品牌 质量排名

8 May 2002 Internal T.I. 2002-0135737 F- REGIME DE CONGE A TRAITEMENT DIFFERE-- summary under Subparagraph 6801(a)(vi) Summary Under Tax Topics- Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(vi) s. 6(11) income recognition when apparent that the leave would not commence within 6 years/ Reg. 6801(a)(vi) does not to extend 6-year period but deals with leaves over one year A taxpayer joined a deferred salary leave plan pursuant to which the deferral period was from September 1, 1994 to September 1, 1997 and the leave was to be taken from September 1, 1997 to September 1, 1998. ... In 2002, the employer plans to pay the employee the amounts deferred over a 3-year period. ... The Directorate further observed: [S]ubparagraph 6801(a)(vi) … does not allow the inclusion of deferred amounts to be extended where the leave has not commenced within the maximum period allowed pursuant to subparagraph 6801(a)(i) …. ...

18 January 2002 External T.I. 2001-0092665 F- AUTOMOBILE-VEHICULE PUBLICITAIRE-- summary under Automobile Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Automobile automobile status turns on design, not use (here, only for advertising) An advertising company acquired motor vehicles which it modified for use, e.g., in vehicular traffic, for advertising the products of its clients. In indicating that the vehicles likely qualified as “automobiles,” CCRA stated that this determination turned on “the design of these motor vehicles and not … their use.” ...

1 March 2002 External T.I. 2002-0118215 F- ACTIONS EMISES GRATUITES AUX EMPLOYES-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) s. 7 rules applicable to shares issued for no consideration to employees Before going on to describe the application of the ss. 7(1.1) and 110(1)(d.1) rules to shares issued for no consideration by a CCPC to employees, CCRA stated: [T]he provisions of section 7 … which deem a benefit to have been received by an employee by reason of employment, are applicable where a corporation has issued shares of its capital stock to its employees for no consideration. ...

20 March 2002 External T.I. 2001-0113815 F- TVQ SUR PRIMES D'ASSURANCE- SALAIRE-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employee would not be credited with a contribution on paying Quebec sales tax on wage loss plan premiums/ the employer paying them would not be a contribution Under a wage-loss insurance plan whose premiums are paid in full by the employees, the employer pays the 9% Quebec sales tax on those premiums. CCRA stated: [T]he employer's payment of sales tax on insurance premiums [is] a taxable benefit to the employee pursuant to paragraph 6(1)(a) …. ...

11 April 2002 External T.I. 2002-0125675 F- REER DECOUVERT BANCAIRE-- summary under Paragraph 146(4)(a) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(4)- Paragraph 146(4)(a) bank overdraft due to admin fee charge to RRSP could constitute money borrowed from the trust An RRSP (apparently holding its cash in a bank account held on its behalf) goes into overdraft as a result of an administrative fee charged to it. CCRA stated: [A] bank overdraft may constitute money borrowed from the trust or the use of property of the trust as security for a loan so that paragraph 146(4)(a) or subsection 146(10) could apply. … [T]here is no administrative relief that would allow these two provisions of the Act not to apply. ...

11 April 2002 External T.I. 2002-0125675 F- REER DECOUVERT BANCAIRE-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) overdraft in RRSP bank account due to admin fee charge could represent the use of trust property as loan security An RRSP (apparently holding its cash in a bank account held on its behalf) goes into overdraft as a result of an administrative fee charged to it. CCRA stated: [A] bank overdraft may constitute money borrowed from the trust or the use of property of the trust as security for a loan so that paragraph 146(4)(a) or subsection 146(10) could apply. … [T]here is no administrative relief that would allow these two provisions of the Act not to apply. ...

25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) amount paid by corporation on conversion of convertible debentures was the stated capital of the issued shares, being the debentures’ face amount, so that no s. 20(1)(f) deduction The issuer, whose convertible debentures were converted, sought to take a ¾ deduction under s. 20(1)(f) based on the excess of the market value of the shares into which the debentures were converted over the face amount of the debentures. ...

16 August 2002 Internal T.I. 2002-0156577 F- ASSURANCE- INVALIDITE- PARITE-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) previous contributions could be deducted from subsequent equalization adjustment received In finding that a taxpayer could deduct contributions made to a disability insurance plan between 1990 and 2001 from an equalization adjustment received in 2001 that related to disability insurance benefits received by the taxpayer in 1988, the Directorate stated: [T]he wording of the Act does not restrict the deductibility of contributions made between 1990 and 2001, even though they were made after the first benefits were paid in 1988 …. ...

7 November 2002 External T.I. 2002-0168795 F- REER TRANSFERT D'ACTIONS AU RENTIER-- summary under Subsection 146(8) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8) shares can be distributed out of RRSP to annuitant – but with their FMV being included as a benefit CCRA indicated that shares held in an RRSP could be transferred to a non-registered account of the annuitant, but that this would result in the FMV of the transferred shares being included in the annuitant’s income as a benefit. ...

9 May 2002 Internal T.I. 2002-0135307 F- Application du paragraphe 39(2)-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) distribution by Delaware subsidiary that did not result in s. 40 application thereby did not engage s. 39(2) The Directorate found that s. 39(2) did not apply to a cash distribution made by a Delaware subsidiary of the taxpayer out of that subsidiary’s contributed surplus (that likely was a dividend for ITA purposes), stating: [S]ubsection 39(2) cannot apply in respect of a transaction that does not result in a gain or loss for the purposes of section 40. In this case, given that [the Delaware subsidiary] did not dispose of any property when the Surplus was repatriated, it follows that this transaction did not result in a gain within the meaning of section 40 …. ...