Search - 2002年 抽纸品牌 质量排名

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS-- summary under Qualifying Home Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home Regarding the purchase of a unit that consisting of a leasehold interest in the property and a number of shares in the corporation that owns the property, CCRA noted that advance rulings had found that a unit consisting of a leasehold interest and shares, and giving its holder the right to the personal enjoyment of the housing unit would be a housing unit for the purposes of the definition of "principal residence", and that the acquisition of such a unit could qualify as a qualifying home for HBP purposes. ...

5 September 2002 External T.I. 2002-0147315- PARTNERSHIP AS A PARTNER & 98 (3)-- summary under Subsection 98(3) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(3) lower-tier partnership wind-up Can s. 98(3) be used where one (or all) of the partners in the particular partnership are themselves partnerships? ...

14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property-- summary under Agency Summary Under Tax Topics- General Concepts- Agency criteria applied for determining presence of agency Before confirming that ticket sales receipts of the taxpayer may have been generated as agent for charitable organizations, so that they did not generate income to the taxpayer, CCRA stated: In general, the CCRA agrees to recognize a principal-agent relationship between persons for tax purposes provided that: the relationship between the persons concerned is legally one of principal-agent; this implies, among other things, that the transactions relating to the agency are effective and complete from a legal standpoint; this relationship arises from a prior formal agreement and does not constitute an ex post facto arrangement; this relationship does not contravene any legislation; the relationship is not a sham; the relationship is disclosed to the CCRA and the relevant documents are provided to the CCRA at the appropriate time (generally when the relevant tax returns are filed); the facts of the particular situation support the existence of the principal-agent relationship between the persons concerned. ...

4 November 2002 External T.I. 2002-0158885 F- Alloc. of Safe Inc. & Disc. ...

18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

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 …. ...

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 …. ...

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" …. ...

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). ...

25 January 2002 External T.I. 2001-0112985- EBP-- summary under Paragraph 7(3)(b) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) EBP purchasing treasury shares of related corp Would s. 7 apply to an employee benefit plan ("EBP") thatacquires treasury shares of a corporation that is related to the employer who contributes to the EBP? ...