Search - 2002年 抽纸品牌 质量排名
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Technical Interpretation - External summary
12 April 2002 External T.I. 2002-0122495 F - PRIME PAYEE SUR OBLIGATION -- summary under Paragraph 7000(1)(b)
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. ...
Technical Interpretation - External summary
11 July 2002 External T.I. 2002-0126795 F - RESSOURCES INTERMEDIAIRES REVENU EX -- summary under Paragraph 81(1)(h)
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 …. ...
Technical Interpretation - Internal summary
30 October 2002 Internal T.I. 2002-0134077 F - ATTRIBUTION DES GAINS EN CAPITAL -- summary under Subsection 74.2(1)
30 October 2002 Internal T.I. 2002-0134077 F- ATTRIBUTION DES GAINS EN CAPITAL-- summary under Subsection 74.2(1) Summary Under Tax Topics- Income Tax Act- Section 74.2- Subsection 74.2(1) indirect transfer where individuals transfer shares to their Holdcos, who transfer such shares to the individuals’ respective spouses Two individuals transferred the shares they held of a particular company to their respective holding companies which, in turn, each disposed of a portion of those shares to the individuals’ respective spouses in consideration for non-interest-bearing notes. ... In finding that s. 74.2(1) applied, the Directorate stated: [W]e consider it possible that an indirect transfer of the individuals' shares to their spouse was effected through their respective holding companies … [so] that the shares disposed of by the spouses … constitute substituted property for the property transferred indirectly by the individuals, Words and Phrases transfer indirectly ...
Technical Interpretation - External summary
12 December 2002 External T.I. 2001-0100755 F - Impact of LCB on Dr and Part IV -- summary under Subsection 129(2)
12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Subsection 129(2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(2) general practice to net dividend refund against unpaid Part I tax Regarding the situation where a CCPC (Bco) was subject to Part I tax for a year but also to a dividend refund (DR), CCRA stated: Where a corporation is required to make a payment under the Act … the CCRA may, instead of paying the amount of the DR for the year, apply the amount of the DR for the year against that other obligation pursuant to subsection 129(2). … In general, the CCRA applies subsection 129(2) on an initial assessment, for example, when a corporation's tax for the year is still unpaid at the time of the initial assessment and the corporation is entitled to a DR for the year. ...
FCA (summary)
Canada v. Société des alcools du Québec, 2002 FCA 69 -- summary under Subsection 120(5)
Société des alcools du Québec, 2002 FCA 69-- summary under Subsection 120(5) Summary Under Tax Topics- Excise Tax Act- Section 120- Subsection 120(5) liquor board was entitled to a full rebate of the FST included in its liquor inventory as the Reg. did not give effect to the legislative intent to avoid double taxation The respondent, which was the Quebec liquor marketing board, sought a full refund of the federal sales tax (imposed at a 19% rate) that was included in the cost of its alcoholic-products inventory on January 1, 1991, but instead was allowed only a rebate equalling the factor of 8.1% applied to the value of that inventory. ... After finding (at para. 45) that “subsection 3(h) is ultra vires in so far as it applies to alcoholic beverages,” and in concluding that the respondent was entitled to a rebate based on the 19% rate if tax actually imposed rather than the 8.1% rate in s. 3(h), Noël J.A. stated (at para. 68): The purpose of the Act in this case is … clear. ...
Technical Interpretation - External summary
10 January 2002 External T.I. 2001-0090325 F - UTILISATION DES VEHICULES -- summary under Subsection 6(2)
10 January 2002 External T.I. 2001-0090325 F- UTILISATION DES VEHICULES-- summary under Subsection 6(2) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(2) commuting in connection with employer requirement to keep vehicle overnight at home was personal use – but not emergency use Outside normal working hours, management employees of a municipality are required to park the automobiles used in its day-to-day operations at their homes for use in quickly responding to emergencies situations such as water leaks or fires. ... Consequently, it is recommended that the employer and employees keep a record of the use of the motor vehicle to clearly distinguish between kilometres driven for personal purposes and kilometres driven for business purposes …. ...
Technical Interpretation - External summary
11 February 2002 External T.I. 2001-0092975 F - MOMENT DE L'INCLUSION DANS LE REVENU -- summary under Timing
11 February 2002 External T.I. 2001-0092975 F- MOMENT DE L'INCLUSION DANS LE REVENU-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing retroactive fee increases were not income until that date that the Order in Council ordering their payment took effect On May 2, 2001, a Quebec Order in Council, which took effect on June 1, 2001, provided that there would thereafter be paid to Quebec pharmacist owners three payments to retroactively increase their fees for January 1, 1999 to December 31, 2000, from January 1, 2001 to March 31, 2001 and from April 1, 2001 to May 31, 2001. In finding that the retroactive fee increases were not income until Juane 1, 2001, CCRA stated: According to the jurisprudence, an amount is receivable when a taxpayer has a definite right to receive it, even if it is not necessarily due. … We consider that the amount is determined when it is sufficiently determinable or where it can be reasonably estimated. … [T]he increases in a pharmacist-owner's fees for services for the period from January 1, 1999 to May 31, 2001 are amounts receivable as of June 1, 2001 and... they must be included in the computation of the pharmacist-owner's income in the taxation year that includes June 1, 2001. ...
Technical Interpretation - Internal summary
2 May 2002 Internal T.I. 2002-0122607 F - BIENS A USAGE PERSONNEL -- summary under Regulation 1102(2)
2 May 2002 Internal T.I. 2002-0122607 F- BIENS A USAGE PERSONNEL-- summary under Regulation 1102(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Regulation 1102(2) effective severance for ITA purposes of land and building by Reg. 1102(2) does not apply to personal-use property On the disposition by an individual of a cottage which is a personal-use property (“PUP”) but not his principal residence, he realizes a capital gain of $15,000, which is attributable to a $25,000 gain on the land, and a $10,000 loss on the building. In finding that this does not signify that he has realized a $25,000 gain on the land, and a $10,000 loss on the building which is denied by s. 40(2)(g)(iii), the Directorate stated: Where a building constitutes depreciable property … [Reg. 1102(2)] has the effect of splitting the property into two for the purposes of the Act, namely the land and the building. In the case of a cottage that is a PUP, we are of the view that the land and the building will remain one and the same property for tax purposes if they constitute one and the same property for legal purposes. … [Here] the taxpayer will realize a capital gain of $15,000 on the disposition of his property. ...
Technical Interpretation - Internal summary
28 June 2002 Internal T.I. 2002-0132427 F - RDTOH -- summary under Subsection 129(1)
28 June 2002 Internal T.I. 2002-0132427 F- RDTOH-- summary under Subsection 129(1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1) RDTOH reduced by dividend refund even if time limit for claiming the dividend refund has passed Portfolioco, which had a RDTOH account on December 31, 1997 of $200,000, paid a taxable dividend of $300,000 in its taxation year ended December 31, 1997, but did not file its return for that year within three years after the end of that taxation year, so that CCRA did not pay any dividend refund to Portfolioco. ... For the purposes of subsection 129(3) … the "dividend refund" means the amount equal to the lesser of the amounts set out in subparagraphs 129(1)(a)(i) and (ii). Consequently … the amount of Portfolioco's RDTOH account for its 1998 taxation year would be reduced by the $100,000 dividend refund that would have been made by the CCRA had Portfolioco filed its return of income in accordance with paragraph 150(1)(a). ...
Technical Interpretation - External summary
4 December 2002 External T.I. 2002-0139345 F - REVENUS D'INTERETS -- summary under Paragraph 118(1)(b)
4 December 2002 External T.I. 2002-0139345 F- REVENUS D'INTERETS-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) income of dependant child includes interest income generated from tax-free receipts Following the death of their mother in a car accident, children received a lump-sum payment from the Société d'assurance automobile du Québec (the "SAAQ"), which was placed in a trust account until they attained the age of majority. ... Finally, for purposes of calculating the … paragraph 118(1)(b) [credit], the individual must take into account the dependant's net income. ... In addition … monthly CSST benefits are also part of the dependant's net income, even if those benefits are deducted in computing the dependant's taxable income. ...