Search - 2005年 抽纸品牌 质量排名

6 January 2005 External T.I. 2004-0088791E5 F- Paragraphe 4803(2) du Règlement-- summary under Subsection 4803(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 4803- Subsection 4803(2) Reg. 4803(2) satisfied if any of its paragraphs is satisfied CRA indicated, based on the meaning of “or”: [T]he conditions listed in paragraphs 4803(2)(a) to (d) … are not cumulative. ...

3 May 2005 Internal T.I. 2005-0120021I7 F- Pension de retraite provenant de la France-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 pension exemption under French Treaty continues to apply in the hands of surviving spouse The Directorate indicated that the exemption under Art. XVIII(1) of the Canada-France Convention for “[p]eriodic or non-periodic pensions … arising in [France] and paid in respect of past employment to a resident of [Canada]” applied to the surviving spouse of an individual (also, a Canadian resident) who had become entitled to the pension by virtue of previous employment in France. ...

26 August 2005 Internal T.I. 2005-0131171I7 F- Alinéa 18(1) e) de la LIR-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense no expense incurred for maintenance obligation until contractual obligation to someone A maintenance obligation to landlords did not give rise to a current deduction since no contractual obligation with specific counterparties had been entered into. The Directorate stated: Burnco states that "an expense within the meaning of paragraph 18(1)(a) … is an obligation to pay a sum of money. ...

7 October 2005 Roundtable, 2005-0140891C6 F- Disposition d'une immobilisation-- summary under Paragraph 14(1)(b) Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(1)- Paragraph 14(1)(b) illustration of application of formula where the vendor of goodwill previously acquired it in a NAL transfer at a gain to the transferor Opco transferred business assets, including goodwill with a nil CEC and a $1 million FMV to a new subsidiary ("Newco"). ... Under element A of the formula in the CEC definition of CEC, the balance in Newco's CEC account as at December 31, 2003 was $500,000, reflecting a reduction for ½ of such s. 14(1)(b) inclusion. ...

21 March 2005 Internal T.I. 2005-0119961I7 F- CCPC STATUS-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date effective date of transfer of shares (entailing acquisition of control) cannot precede determination of essential contract elements USco disposed of 50% of the shares of Canco to another corporation ("Holdco" – that was a Canadian-owned Canadian corporation), "retroactive" to a particular date. ...

11 April 2005 External T.I. 2004-0091721E5 F- Usufruit d'un bien immeuble situé en France-- summary under Paragraph 248(3)(a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(3)- Paragraph 248(3)(a) usufructuary of rental property received the rental income under s. 108(5)(a) as deemed trust income beneficiary A resident of Canada gifted to his daughter, also resident in Canada, the bare ownership of an income property located in France, while retaining the usufruct of the property. CRA noted that the daughter would receive the net rental income as the income beneficiary of a deemed trust under s. 248(3) (so that such income was deemed to be income from property under s. 108(5)(a)) – except that when the usufruct was extinguished, there would be a dissolution of the deemed trust to which s. 107(2) would apply, so that thereafter the bare owner would become subject to tax on the rental income. ...

24 May 2005 External T.I. 2005-0121291E5 F- Processing in Canada of ore-- summary under Clause Subparagraph 1204(1)(b)(iii)(A) Summary Under Tax Topics- Income Tax Regulations- Regulation 1204- Subsection 1204(1)- Paragraph 1204(1)(b)- Subparagraph 1204(1)(b)(iii)- Clause Subparagraph 1204(1)(b)(iii)(A) second crushing of nickel ore at the surface generated gross resource profits Mineco crushes nickel ore underground in its mine. ... CRA stated: [T]he revenues that Opco would earn in a particular year from the Second Crushing activity could be included in computing its GRP for that year under clause 1204(1)(b)(iii)(A) … since they could constitute revenues for the year from the processing in Canada of ore derived from mineral resources in Canada that would not be mined by Opco to any stage that is not beyond the prime metal stage or its equivalent. ...

19 May 2005 External T.I. 2005-0113681E5 F- Dédommagement pour congédiement injustifié-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) court-ordered reinstatement order gives rise to employment income In response to a query concerning the tax treatment of compensation paid to an employee for wrongful dismissal, CRA stated: [W]here, pursuant to a court order or out-of-court settlement, a dismissed employee is retroactively reinstated in the employee’s employment and the employer is required to pay the employee compensation for damages, in lieu of salary and other employment benefits (including compensation for expenses incurred by the employee in seeking new employment), the amount paid to the employee should be treated as taxable employment income pursuant to subsection 5(1) or section 6 and not as a retiring allowance. This position also applies where there is no availment by the taxpayer of the right to reinstatement. … [C]ompensation identified as interest (including pre-judgment interest and post-judgment interest) is taxable as interest income pursuant to paragraph 12(1)(c) if it is interest by its nature. ...

9 June 2005 Internal T.I. 2005-0115481I7 F- Avantages imposables/voyages-- summary under Paragraph 200(2)(g) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(2)- Paragraph 200(2)(g) T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers The Corporation sells products to incorporated or unincorporated retailers, awards them dollar-amount points based on their volumes of purchases, with the retailers then rewarding their employees or shareholders (or themselves, if unincorporated) with trips that the Corporation paid for, with the dollar points accumulated in favour of the retailers being reduced accordingly. ...

24 June 2005 External T.I. 2005-0126251E5 F- Montants alloués pour personne handicapée-- summary under Subsection 118(6) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(6) taxpayer could not claim the s. 118(1)(d) credit since she no longer was supporting her daughter Could the taxpayer claim the wholly-dependent person tax credit for disabled dependants over 18 years of age under s. 118(1)(d) for her daughter who was now over 18 years of age, given that the daughter had been placed in a specialized centre since she was two and a half years old and the taxpayer was no longer having to pay for her daughter as she was receiving social assistance benefits? CRA stated: Generally, a person is dependent on an individual if the individual provides for the individual's basic needs or necessities on a regular and consistent basis … [so that the taxpayer] cannot claim the wholly dependent person tax credit for dependants with physical or mental disabilities. ...