Search - 2005年 抽纸品牌 质量排名

7 October 2005 APFF Roundtable Q. 13, 2005-0141061C6 F- Purchase of Shares by Subsidiary- Sec. 84.1 & 245 Unedited CRA Tags 84.1 245(2) 251(1) Principal Issues: An individual ("X") owns 20% of the issued and outstanding shares of the capital stock of an operating corporation ("Opco"). ... X détient dans le capital-actions de Opco pour 200 000 $ payés comptant. ... Stéphane Prud'Homme (613) 957-8975 October 7, 2005 2005-014106 ...

21 November 2005 External T.I. 2005-0143231E5- Terminal Charge / ONT Tax Reduction Unedited CRA Tags 6(2) Principal Issues: (a) The taxable status of a $XXXXXXXXXX terminal loss incurred by an employer in respect of a leased automobile at the end of the lease- should the entire amount of the terminal loss be included in the employee's income as a taxable benefit? ... Randy Hewlett XXXXXXXXXX 613-957-2049 2005-014323 November 21, 2005 Dear XXXXXXXXXX: Re: Automobile Benefit / Ontario Tax Reduction We are writing in response to your letter of April 30, 2005, which was sent to the CRA's Summerside Taxation Center. ...

24 March 2005 Internal T.I. 2005-0115921I7- Specified debt obligations & loan originating cost Unedited CRA Tags 248(1) 142.2(1) Reg 9004 Reg 8604 Principal Issues: (a) Are the taxpayers restricted financial institutions ("RFI") within the meaning of paragraph (e) of the definition in subsection 248(1)? ... March 24, 2005 XXXXXXXXXX TSO HEADQUARTERS Technical Applications and P. Diguer CGA Valuations Division (613) 957-8953 Attention: XXXXXXXXXX 2005-011592: XXXXXXXXXX ("A Co" XXXXXXXXXX ("Leaseco") This is in response to your e-mail ("Request") dated February 14, 2005 in which you request our views in regard to the above referenced taxpayers proposed change in the method of reporting of expenses incurred in connection with the acquisition of certain properties for purposes of the Income Tax Act (Canada) (the "Act"). ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election Unedited CRA Tags 83(2) 184(2) 184(3) 83(3) Principal Issues: 1) In a given fact situation, a corporation ("XCO") filed in 2001 an election under subsection 83(2) of the Act. ... Le 2 mai 2005 Services Fiscaux de Montérégie-Rive-Sud Direction des décisions Service à la clientèle en impôt 3250, boulevard Lapinière S. ... Le montant de ce choix aurait excédé le montant du CDC de XCO à ce moment d'environ XXXXXXXXXX $. ...

17 October 2005 External T.I. 2005-0136781E5- Scholarship, Tuition, & Education Tax Credits Unedited CRA Tags 56(1)(n) 56(3) 118.5(1) 118.6(2) Principal Issues: 1) Can a scholarship exemption be obtained where employment ends, and the employee receives an amount from their employer termed a "retraining allowance", which is paid directly to a school outside Canada for a one-month ESL teacher training course? ... Reasons: 1) 56(1)(n) of the Income Tax Act excludes as scholarships, bursaries etc, amounts received in the course of business, or amounts received in respect of or in the course of, or by virtue of an office or employment and therefore, are ineligible for the taxpayer's scholarship exemption for the year computed under subsection 56(3). 2) Course taken outside Canada does not meet 13-week length requirement to be eligible for tuition and education tax credits. 2005-013678 XXXXXXXXXX Darlene Green (613) 957-2082 October 17, 2005 Dear XXXXXXXXXX: Re: Scholarship Exemption This is in response to your e-mail correspondence of June 14, 2005 wherein you asked whether you are entitled to a scholarship deduction for the 2001 taxation year in respect of an amount you received as a "retraining allowance" at the end of your employment, where the amount was paid by your employer directly to a school in Spain as tuition for you to attend a one-month ESL teacher training course. ... In certain situations, a taxpayer may be able to claim a tuition tax credit, and / or an education tax credit in respect of taxable employer-paid tuition. ...

5 December 2005 External T.I. 2005-0155331E5- XXXXXXXXXX 2006 Meeting- Q & A's Unedited CRA Tags 18(4) 95(6) Principal Issues: Questions & Answers provided by Wayne Adams at 2006 XXXXXXXXXX Meeting Limited partnerships and thin capitalization Various questions re 95(6) Reverse hybrids and treaty Position: See body of memo Reasons: See body of memo On October 24, 2006, Wayne Adams, Director General of the Income Tax Rulings Directorate, Canada Revenue Agency, attended the XXXXXXXXXX meeting and responded to the following questions: 1. ... Completion of the ITTN has been postponed pending the outcome of the Univar Canada Ltd case that was heard in the Tax Court of Canada in May 2005. However, some of the draft examples were discussed during the CRA roundtable at the May 2005 IFA Conference in Toronto. ...

2 June 2005 External T.I. 2005-0116801E5- Airplane Lease Costs & Withholding Tax Unedited CRA Tags 6(1)(a) 15(1) 212(1)(d)(xi) Principal Issues: Canco leases an airplane from USco for use in the shareholder's business travel. 1. ... XXXXXXXXXX 2005-011680 Kathryn McCarthy, CA June 2, 2005 Dear XXXXXXXXXX: Corporate Airplane Lease Costs and Withholding Tax This is in reply to your letter dated February 16, 2005, concerning the above noted subject matter. ...

17 June 2005 External T.I. 2005-0134441E5- Labour Association Annulment & Bank Balance Unedited CRA Tags 8(1)(i) 8(5) 149(1)(k) Principal Issues: Whether the payment of the labour association's bank balance after its annulment to its current members would affect its non-taxable status Position: No. ... In addition, since the association's dues were reasonable and its bank balance is not excessive, subsection 8(5) would have no application to disallow any deductions previously claimed by the of your association 2005-013444 XXXXXXXXXX Charles Rafuse 613-957-8967 June 17, 2005 Dear XXXXXXXXXX: Re: Labour Association Annulment and Bank Balance This is in reply to your letter of May 24, 2005, concerning the annulment of the XXXXXXXXXX and the excess funds in the association's bank account. ...

1 December 2005 External T.I. 2005-0155975E5- Cellular Phone Airtime Minutes & Taxable Benefits Unedited CRA Tags 6(1)(a) Principal Issues: Whether an employee's personal use of airtime minutes of an employer provided cellular phone plan represent a taxable benefit under paragraph 6(1)(a) Position: Question of Fact. ... N30 3rd Floor Rob Ferrari Victoria BC V9A 7N2 (613) 957-2138 December 1, 2005 Dear Ms. Dibb: Re: Employees' Personal Use of Employer Provided Cellular Phone Airtime This letter is in reply to your e-mail of October 19, 2005 in respect of the above noted matter. ...