Search - 2002年 抽纸品牌 质量排名

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 …. ...

21 March 2002 External T.I. 2001-0115265 F- 89(1)(c.1)(i)&(c.2)(i) Capital Div. ... Furthermore … paragraph 83(2)(a) deems [an s. 83(2)] dividend to be a "capital dividend" to the extent of the amount of the corporation's CDA immediately before the particular time. ...

7 January 2002 External T.I. 2001-0089585 F- AUTOMOBILE DETENUE EN COPROPRIETE-- summary under Subsection 6(2) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(2) standby based on corporation’s cost where it purchases a co-ownership interest in the automobile A shareholder-employee who uses his $30,000 automobile 75% for business, and 25% for personal purposes sells a 75% interests in the automobile to his corporation for $22,500. CCRA indicated that the standby benefit would be computed based on the corporation’s cost of $22,500 and the number of 30-day periods during which the automobile is available to the employee – unless the kilometres driven personally was fewer than 1,000 kilometres per month and all or substantially all (i.e., 90%) of the distance travelled by the automobile during the total number of days in the year it was made available to the employee was in the performance of the duties of his employment. ...

18 January 2002 External T.I. 2001-0092665 F- AUTOMOBILE-VEHICULE PUBLICITAIRE-- summary under Subparagraph (e)(i) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(i) vehicle cosmetically altered for advertising purposes is not thereby used to transport goods or equipment An advertising company acquired motor vehicles which it modified for use, e.g., in vehicular traffic, for advertising the products of its clients. ... (e) exclusion, stating that “the goods or equipment to be transported by the motor vehicle … must be distinct from the motor vehicle itself.” ...

22 January 2002 Internal T.I. 2001-0100537 F- ENTENTE TEMPORAIRE PENSION ALIMENTAIRE-- summary under Commencement Day Summary Under Tax Topics- Income Tax Act- Section 56.1- Subsection 56.1(4)- Commencement Day cessation of temporary support variation agreement would effectively reverse the commencement day A temporary agreement signed by Monsieur and Madame indicating a change in the amount of support and custody of one of the children thereby caused a commencement day when the first payment was made, so that the new rules commended to apply. ... This has the effect of applying the old rules on support, which means that Monsieur could deduct the amounts paid and Madame would be taxed on the amounts received under that judgment …. ...

21 February 2002 External T.I. 2002-0123905- ADVANCES RECEIVED BY A CASH BASIS FARMER-- summary under Paragraph 28(1)(a) Summary Under Tax Topics- Income Tax Act- Section 28- Subsection 28(1)- Paragraph 28(1)(a) amounts deemed to be received under s. 12(1)(a) are income under s. 28(1)(a) whereas loans are excluded After stating that “we have found that cash advances received for crops are generally income when received” but that “advances received under the Agricultural Marketing Programs Act are loans and income is reported when the crops securing the loans are sold and the proceeds used to repay the loans,” CRA stated that the particular amount received: was either income from sales on December 1 and 2, 1999, or received in respect of future sales and required to be included in income pursuant to paragraph 12(1)(a) of the Income Tax Act (the "Act"). In either case, the entire amount should be included in income on December 15, 1999, the date the advance was received … [per] paragraph 28(1)(a). ...

25 February 2002 External T.I. 2000-0046485 F- Majoration et Immobilisation-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) co-operative use of s. 88(1)(d) bump by targets and purchasers could entail acting in concert Planning to equalize assets of two target corporations (Aco and Bco) in connection with their sale to two purchasers (HoldcoA and HoldcoB)- which entailed a preliminary s. 85(1) rollover of equaling property by Aco and Bco, followed by the purchase of Aco by HoldcoA, and Aco’s s. 88(1) wind-up into HoldcoA to bump the preferred shares received on such s. 85(1) rollover, followed by a sale of the bumped shares by HoldcoA to HoldcoB – was considered to likely entail all the parties acting in concert so that they could not be considered to be dealing at arm’s length. ...