Search - 2002年 抽纸品牌 质量排名

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FCA (summary)

Hogg v. Canada, 2002 DTC 7037, 2002 FCA 177 -- summary under Paragraph 8(1)(h.1)

Canada, 2002 DTC 7037, 2002 FCA 177-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) expenses incurred by a judge in travelling between home and court room were not incurred in the course of the employment The taxpayer, who was a judge of the Ontario Provincial Court, Criminal Division, was not able to deduct the cost of travelling to and from his home to the Court House in his own car or of travelling in his car when presiding away from the Court House or when attending meetings in other locations. Nadon J.A. stated (at para. 12): "... a plain reading of both the French and English text of paragraph 8(1)(h.1) of the Act makes it clear that the words 'motor vehicle expenses incurred for travelling in the course of the office...' necessarily require that these expenses be incurred by the taxpayer while performing the duties of his office. ...
Conference summary

10 November 2002 Roundtable, 2002-0156845 F - CONGRE 2002 APFF -- summary under Subsection 7(1.1)

10 November 2002 Roundtable, 2002-0156845 F- CONGRE 2002 APFF-- summary under Subsection 7(1.1) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.1) realization of s. 7(1.1) gain on shares’ disposition even though they had lost most of their value An employee exercised stock options in 2001 after the CCPC employer became a public corporation and the shares had substantially appreciated and then sold the shares a year later when they had lost most of their value. CCRA confirmed that the employee realized a taxable benefit in 2002 based on the 2001 value, and realized a capital loss at the same time on the shares’ disposition. ...
Article Summary

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper -- summary under Subsection 39(2.02)

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Subsection 39(2.02) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2.02) Background to s. 39(2.01) (pp. 13-14 Many Canadian companies have or had significant accrued foreign currency gains in their US dollar denominated debts, particularly where the debts were originally issued in 2001 or 2002…. ...
Article Summary

Catherine Brown, Arthur J. Cockfield, "Rectification of Tax Mistakes Versus Retroactive Tax Laws: Reconciling Competing Visions of the Rule of Law", Canadian Tax Journal, (2013) 61:3, 563-98 -- summary under Rectification & Rescission

[fn 39: S & D International Group Inc. v. Canada (Attorney General), 2011 ABQB 230, at paragraph 106.] ... In order to get rectification it is necessary to show that the parties were in complete agreement on the terms of their contract, but by an error wrote them down wrongly; and in this regard, in order to ascertain the terms of their contract, you do not look into the inner minds of the parties into their intentions any more than you do in the formation of any other contract. ... Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, at paragraph 31] (the other non-tax-related decision): (1) the existence and content of the inconsistent prior oral agreement; (2) that the party seeking to uphold the terms of the written agreement knew or ought to have known about the lack of correspondence between the written document and the oral agreement, in circumstances amounting to fraud or the equivalent of fraud; and (3) "the precise form" in which the written instrument can be made to express the prior intention. ...
Technical Interpretation - External summary

12 June 2002 External T.I. 2002-0138625 - REGISTERED INVESTMENTS FUTURES CONTRACTS -- summary under Subsection 4901(1)

In accordance with [Reg.] 4901(1) a prescribed investment for a registered investment is a qualified investment for a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in [ss.] 146(1), 146.3(1) and section 204 [and Reg.] 4900 …. ... In addition [see] paragraph 21 of IT-320R3 …. ...
Technical Interpretation - External summary

12 June 2002 External T.I. 2002-0138625 - REGISTERED INVESTMENTS FUTURES CONTRACTS -- summary under Paragraph 4900(1)(e)

In accordance with [Reg.] 4901(1) a prescribed investment for a registered investment is a qualified investment for a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in [ss.] 146(1), 146.3(1) and section 204 [and Reg.] 4900 …. ... In addition [see] paragraph 21 of IT-320R3 …. ...
Technical Interpretation - Internal summary

9 April 2002 Internal T.I. 2001-0112817 F - RESIDENCE PRINCIPALE - VENTE D'UN DUPLEX -- summary under Paragraph (e)

9 April 2002 Internal T.I. 2001-0112817 F- RESIDENCE PRINCIPALE- VENTE D'UN DUPLEX-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) duplex land allocated between rental and principal residence generally based on the floor areas of the respective building portions Where the owner of a duplex occupied one unit as his principal residence and rented out the other unit, on his sale of the duplex could he treat the entire gain on the land as exempted by the principal residence exemption? ... Our position is supported by Berkovic 83 DTC 335 and …. Mitosinka …. ...
Technical Interpretation - Internal summary

25 February 2002 Internal T.I. 2001-0114167 F - DOMMAGES - DISCRIMINATION -- summary under Retiring Allowance

25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance compensation under the CHRA for lost wages and expenses would be a retiring allowance reasonable (e.g., under $5,000) compensation for pain and suffering would be non-taxable After filing a complaint pursuant to the Canadian Human Rights Act (the “CHRA”), the taxpayer received a lump sum from his employer pursuant to an out-of-court settlement that did not allocate the amount. ... …[W]e have asked for information concerning human rights at the provincial level. We found that human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...
Technical Interpretation - External summary

4 April 2002 External T.I. 2001-0103525 F - Identical Property -- summary under Paragraph (i)

CCRA stated: [T]he conversion or exchange rights attached to the newly acquired Class A shares and permitting the exchange of such shares for Class B shares would technically constitute a "right to acquire" the substituted property …. These conversion or exchange rights would therefore be deemed to be property identical to the Class B shares previously disposed of by the Taxpayer. Consequently, the loss incurred by the Taxpayer and resulting from the disposition of the Class B shares would be a "superficial loss" …. ...
Technical Interpretation - External summary

21 November 2002 External T.I. 2002-0156565 F - INTERETS HYPOTHEQUE SUR RESIDENCE -- summary under Subsection 20(3)

21 November 2002 External T.I. 2002-0156565 F- INTERETS HYPOTHEQUE SUR RESIDENCE-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) interest on new home mortgage deductible if used to pay off mortgage on old home that had been used for income-producing purposes On a sale of the taxpayer's home, the mortgage loan for which the interest was deductible pursuant to s. 20(1)(c) because the loan proceeds had been used to acquire a commercial rental building, must be repaid. ... CCRA responded: [T]he situation is similar to Grenier …. Consequently, subject to additional facts to the contrary, the interest paid could be deductible pursuant to paragraph 20(1)(c). ...

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