Search - 2002年 抽纸品牌 质量排名

24 May 2002 Internal T.I. 2002-0130667 F- REGIME PRESTATION EMPLOYES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts “received” under EBP if unrestricted right to receive Under a provision of an employee benefit plan which was assumed, for discussion purposes, to be grandfathered from the salary deferral arrangement rules, an employee could elect at the time of retirement to receive all amounts accumulated in the plan either immediately or in instalments (through the purchase of an annuity). ...

4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree After finding that a lump-sum payment to cover support-payment arrears could be considered as an amount payable on a periodic basis, even though it was less than the amount initially anticipated, the Directorate went on to note: The Court of Appeal judge decided to credit the amount of $XXXXXXXXXX, which consisted of expenses incurred by Monsieur for the benefit of the child, against the balance of the arrears owed to Madame by Monsieur. ...

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. ...

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. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...

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. ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...