Search - 2002年 抽纸品牌 质量排名

18 April 2002 Internal T.I. 2002-0118827 F- DEBENTURES CONVERTIBLES-- summary under Subsection 18(9.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.1) straight-line or present value method may be used in amortizing premium, and must relate to interest Regarding the potential application of s. 18(9.1) to a premium paid on the early cash redemption of convertible debentures, the Directorate indicated: “if part of the penalty relates to something other than interest, such as debt administration costs, it would not be deductible pursuant to subsection 18(9.1)” – although that did not appear to be the case here regarding s. 18(9.1) covering the amount of a penalty or bonus to the extent that it does not exceed the amount of the total interest that would otherwise have been payable but for the reduction or repayment, the “word ‘value’ in subsection 18(9.1) may therefore be interpreted as meaning the total value and not the present value of future interest payable.” ...

23 December 2002 Internal T.I. 2002-0176087 F- LIMITE APPLICABLE TRANSFER DANS REER-- summary under Variable C Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.11)- Paragraph 146.3(6.11)(b)- Variable C Variable C included the deemed benefit under s. 146.3(6.1) Following the death of the annuitant of a RRIF, all the plan funds were transferred to the estate (which was named in the will as the beneficiary) and then, as directed by the will, the estate transferred all such funds 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). ... This proposition can be inferred from the position taken by Canadian courts regarding the scope to be given to a deeming provision. … Thus, even if the deceased annuitant did not actually receive an amount representing the value of his RRIF, by the effect of the [s. 146.3(6)] deeming rule, the Act leads us to consider this to be so. ...

Y filed his T1 income tax returns for the 2001, 2002, and 2003 taxation years at the same time in the 2004 calendar year. In his 2001, 2002 and 2003 taxation years, he failed to report income of $18,000, $500 and $1,000, respectively. ... Y's unreported income under the first scenario …. Regarding the second assumption, CRA stated: [I]f the failure to report an amount to be included in Mr. ...

After a finding by the International Trade Tribunal that there was not a current material injury to the US lumber producers, the Corporation was released by the US government from its potential obligations regarding the CADD for the years 2001 and 2002, in 2002, it repaid an amount corresponding to the CADD in question to its suppliers. In finding that the Corporation was not entitled to a deduction in 2001 for the CADD amounts pursuant to s. 20(1)(vv), and before going on to find that s. 18(1)(e) denied a s. 9 deduction, the Directorate stated: Paragraph 20(1)(vv) … allows for the deduction of such duties as long as they are paid. … In the current context, [“paid’] … means "to discharge a debt". ... Consequently, we are of the view that the provisions of paragraph 20(1)(vv) do not apply …. ...

X had not declared an amount in his 2004 return (the "first criterion at issue "). ... X failed to report an amount in 2002, one of the three taxation years preceding 2004 (the "second criterion at issue"). ... X would be subject to a penalty pursuant to subsection 163(1) for his 2004 taxation year …. ...

During the 2002 to 2005 period, the individual incurred annual tuition fees for which credits under s. 118.5 were not claimed, so that for 2006, there were unused tuition tax credit amounts under s. 118.61. ... The Directorate stated: Where a bankrupt individual files a consumer proposal, section 66.4(2) of the BIA provides, among other things, that the approval or deemed approval by the court of the consumer proposal operates to annul the bankruptcy and to revest the property of the individual, unless the terms of the consumer proposal otherwise provide. … [T]he discharge from bankruptcy is not retroactive to the time the individual was declared bankrupt but … is effective from the date the proposal is approved by the court. … Although section 128 does not recognize proposals filed under the BIA, the discharge from bankruptcy [in] 2005 does not invalidate the filing and assessment of pre- and post-bankruptcy tax returns made prior to the date of discharge. … [T]he individual was bankrupt in the 2003 … 2004 … and the 2005 taxation year[s]. ... Consequently, the individual may carry forward the unused portion of his or her tuition tax credits at the end of the 2005 taxation year … to the 2006 taxation year pursuant to section 118.61. ...

9 February 2012 Internal T.I. 2011-0426871I7 F- Perte au titre d'un placement d'entreprise-- summary under Subparagraph 39(1)(c)(iv) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c)- Subparagraph 39(1)(c)(iv) requirement satisfied where debtor reacquired its status as SBC before becoming bankrupt In 2002, the taxpayer made a loan to a wholly-owned corporation, which used those funds to make a foreign investment, causing it to cease to be a small business corporation ("SBC"). ... The definition of SBC provides that for the purposes of paragraph 39(1)(c), a corporation is a SBC at a particular time when it was a SBC at a time in the 12-month period preceding the particular time. … [I]t would seem that the requirements … respecting a BIL appear to be satisfied. ...

That corporation had no income in 2001 and 2002, and small income in 2003 from software development. Before concluding that “the new corporation did not carry on a business at the time the shares were issued” so that “those shares were not shares of an eligible small business corporation,” CRA noted that there was no evidence that “a software development activity … [had] started at the time the taxpayer invested in the corporation,” and also stated: [T]here may be arguments that the business was started at the time that steps to change the zoning were taken. ...