Search - 2002年 抽纸品牌 质量排名

7 November 2002 CTF Roundtable Q. 1, 2002-0144140- CTF STEWART & WALLS-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit REOP test not applied if no personal element and only tax motivation In response to various questions on the impact of Stewart and Walls including its impact on CCRA’s use of the reasonable expectation of profit test,(“REOP”), CCRA stated inter alia: The REOP test, as it previously applied, will no longer be used to determine if there is a source of income under the Act. ... At this point, a taxpayer's venture will be reviewed and criteria, including those set down in Moldowan, will be considered in determining if the taxpayer intends to carry on an activity for profit and the overall evidence supports that intention. … If a taxpayer is motivated by tax considerations when he or she enters into a business or property venture, this will not detract from the venture's commercial nature or characterization as a source of income under the Act. ...

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. ...

In light of the joint and several liability of the resident contributor under s. 94(3)(d) for unpaid taxes of the trust for its 2020 taxation year, subject to limitation by the “recovery limit” provisions of ss. 94(7) and (8), would the resident beneficiary be liable for such taxes given that the beneficiary did not receive any distributions from the trust in its 2002 taxation year; and would a distribution to the beneficiary in subsequent taxation years affect the Minister’s ability to collect in respect of the trust’s 2020 taxation year? ... The Minister could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...