Search - 2002年 抽纸品牌 质量排名

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in ownership dispute were capital expenditures After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieurs obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

24 May 2002 Internal T.I. 2001-0113597 F- ASSURANCE CONTRE LES MALADIES GRAVES-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) if a clause providing for the return of premiums on death was ancillary, the policy could still qualify as a group sickness or accident insurance plan A term to age 75 critical illness policy provided that in the event of the death of the insured during the period of insurance without having been entitled to the payment of a critical illness benefit, the premiums paid would be refunded up to the sum insured. CCRA indicated that if this return of premium on death clause was ancillary to critical illness insurance, the insurance policy would be a sickness or accident insurance policy – in which case, there would be no taxable benefit under s. 6(1)(a) if it were a group sickness or accident insurance plan. ...

25 July 2002 Internal T.I. 2002-0139877 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) contributions in years 2 and 3 could be deducted from subsequent parity adjustment to contribution made in year 1 In finding that a taxpayer could deduct contributions made to a disability insurance plan between 1989 and 2001 from a parity adjustment received in 2001 relating to disability insurance benefits received in 1988, the Directorate stated: An amount received by reason of a parity adjustment in respect of benefits obtained in the past retains the same nature as the amounts to which it relates. … [T]he wording of the Act would not restrict the deductibility of contributions paid between 1989 and 2001, even though they were paid after the time that triggered the payment of the first benefits in 1988. ...

4 December 2002 Internal T.I. 2002-0138067 F- REMPLACEMENT D'UNE CREANCE PAR UNE AUTRE-- summary under Paragraph 18(9.1)(a) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.1)- Paragraph 18(9.1)(a) financing the repayment of a debt obligation with the proceeds of a borrowing from a different creditor does not constitute a debt substitution A corporation repaid an unsecured debenture with surplus cash and by drawing down on a revolving line of credit. ... The Directorate responded: [I]n order for there to be such a substitution for the purposes of subsection 18(9.1), there must be a substitution between the creditor and the debtor of another obligation for the original obligation. … [Here] there was no replacement of the original obligation by another obligation between the Corporation and the debenture holders. ...

23 December 2002 Internal T.I. 2002-0176087 F- LIMITE APPLICABLE TRANSFER DANS REER-- summary under Subsection 146.3(6.1) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.1) deemed benefit under s. 146.3(6.1) included in amount referred to in s. 146.3(5) All the funds in the RRIF of the deceased annuitant were transferred for the benefit of the financially dependent child of the deceased so that, pursuant to s. 146.3(6.1), the total designated benefit was included in the child’s income under s. 146.3(5). In confirming that the child could transfer the entire amount of the designated benefit to the child’s RRSP, the Directorate stated: [A]mounts deemed to be received from the RRIF by the deceased annuitant by reason of subsection 146.3(6) constitute amounts received for the purposes of subsection 146.3(5). … Consequently, this amount must be taken into account in determining Variable C in the formula in subsection 146.3(6.11). ...

12 March 2002 Internal T.I. 2001-0094067 F- DEDOMMAGEMENT- TITRE DE PROPRIETE-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition damages received for use of a property contrary to the recipient’s co-ownership right were tax-free receipts After his discovery that his separated common-law spouse (Madame) was selling a property in which he had a ½ co-ownership interest, Monsieur obtained a judgment requiring recognition through a deed of his co-ownership interest and a second judgment requiring her to account for her management of the property in the interim, which resulted in Monsieur receiving a lump-sum damages payment. ...

5 March 2002 Internal T.I. 2001-0102757 F- PERTE FINALE-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base cost of moving rental building off land for subsequent sale, in order to construct parking lot and create more space for existing rental buildings, was addition to ACB of land In order to enlarge the parking lot on its existing rental property and improve the visibility of the existing buildings, the taxpayer acquired an adjoining lot with building, incurred costs in relocating that building, capitalized those relocation costs to that building and then sold the building to a third party and claimed a terminal loss most of which represented such capitalized costs. Before concluding that such terminal loss should be denied because the building did not qualify as depreciable property (it was not acquired for rental-income purposes notwithstanding its temporary generation of rents), the Directorate stated: [M]ost of the moving costs … should be added to the cost of the cleared land since the purpose of the move was to clear the land rather than to advantageously locate the building. ...

18 April 2002 Internal T.I. 2001-0105007 F- RECOMPENSE POUR UN SAUVETAGE MARITIME-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) salvage received by crew members was not an exempt windfall A company owning a pilot boat participated with its employed crew in the marine rescue of a vessel in distress, received compensation pursuant to the Shipping Act after suing for compensation, and paid the crew members a portion of the compensation received as a reward for their participation in the marine salvage of the vessel in distress (in accordance with a scale previously established by a UK arbitrator in similar cases). In finding that such compensation was taxable to them (and likely employment income rather than business income), the Directorate stated: [T]he reward received by the crew members was not a windfall …. ...

12 February 2002 Internal T.I. 2002-0119057 F- Perte du décédé et intérêt-- summary under Subparagraph 161(7)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 161- Subsection 161(7)- Paragraph 161(7)(b)- Subparagraph 161(7)(b)(ii) “subsequent taxation year” here and in s. 161(7)(a)(iv.2) refers to the first taxation year of the estate After the estate of Ms. ... It is, furthermore, this taxation year that is referred to in subparagraph 161(7)(a)(iv.2) (also referred to as the subsequent taxation year in that place). … [T]he estate's first taxation year is the subsequent taxation year referred to in subparagraph 161(7)(a)(iv.2) and subparagraph 161(7)(b)(ii). ...

18 April 2002 Internal T.I. 2002-0118827 F- DEBENTURES CONVERTIBLES-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) no s. 20(1)(f)(ii) deduction on conversion of convertible debentures notwithstanding attempt in resolution to fix the issued shares’ stated capital at their market value The corporation, on the conversion by holders of convertible debentures that it had previously issued, passed a resolution stipulating that the stated capital of the shares issued by it on the conversion was equal to the shares’ market value at that time, and took a deduction under s. 20(1)(f)(ii) equal to ¾ of the excess of such market value over the face value of the converted debentures. ...