Search - 2005年 抽纸品牌 质量排名

18 April 2005 External T.I. 2004-0093821E5 F- Fiducie créée par testament-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Testamentary Trust- Paragraph (c)- Subparagraph (c)(i) beneficiary electing not to receive income before it becomes payable does not taint the trust (cf. renouncing income already payable) Under a spouse trust, the spouse has the exclusive and unconditional right to all annual income but it remains in the spouse's discretion to not require the annual payment of all income, and any portion of the income not so distributed to be added to the trust capital distributed to the spouse, at the spouse's discretion, in the same manner as the capital, the spouse being the sole capital beneficiary during the spouse’s lifetime, so that the trustees must distribute all or part of the capital to the spouse at the spouse’s sole request. ... Thus, in such a situation, the trust would no longer be a "testamentary trust" …. ...

8 November 2005 External T.I. 2005-0148091E5 F- Résidence principale-deux unités de condominium-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence two stacked condos connected by an interior staircase constituted two housing units A couple purchased a condo beneath the one they had been occupying as their home and did work to connect the two units by interior staircase. ... On the other hand, if one unit has all the bedrooms and the other unit consists primarily of the kitchen and bathrooms and they are truly used as one unit, the CRA may be more likely to conclude that there is a single unit for purposes of the definition of "principal residence" …. ...

22 December 2005 External T.I. 2005-0151091E5 F- Allocation de retraite- retenue à la source-- summary under Paragraph 100(3)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) confirmation of RRSP deduction limit is not required from the employee for the portion of the retiring allowance that is eligible for deduction under paragraph 60(j.1) In response to a query as to whether the correspondent’s notice of assessment must be provided to the employer so that it can pay the retiring allowance amount into the individual’s RRSP without deductions at source – and whether that amount can be paid into a spousal RRSP or as a repayment of the individual’s home buyers' plan ("HBP"), CRA stated: [T]he employer is not required to withhold tax on the amount of the retiring allowance that it pays directly to an RRSP if the employer has reasonable grounds to believe that the premium is deductible under paragraph 60(j.1) or subsection 146(5) or (5.1) in computing the employee's income for the taxation year in which the retiring allowance is paid. ...

2 November 2005 External T.I. 2004-0093601E5 F- Fiducie au profit d'un mineur-- summary under Paragraph 104(18)(c) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(18)- Paragraph 104(18)(c) can be discretion regarding distribution of capital other than accumulated income CRA comments included: Although s. 104(18) cannot apply if the trust deed provides that the portion of the capital that represents income accumulated for beneficiaries under 21 will be distributed at the discretion of the trustee “the manner in which the other portion of the capital is distributed, such as the initial capital, will have no impact on whether the conditions of subsection 104(18) are satisfied.” ... Specific clauses in the trust deed providing that certain types of payments will constitute income to the trust are acceptable- the “fact that the trust deed provides that certain types of payments will constitute income does not, in and of itself, determine whether the conditions of subsection 104(18) … are satisfied, including the condition referred to in subsection 104(18)(c).” ...

7 January 2008 External T.I. 2007-0225481E5 F- GRIP Addition for 2006-- summary under Subsection 89(7) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(7) GRIP addition from subsidiary resulting from 2001 and 2005 dividends A CCPC (Holdco) received (as its only income during the years 2001 to 2005) a taxable dividend of $400,000 in 2001 from its wholly-owned subsidiary (Opco). Opco's "full rate taxable income" ("FRTI") for each of the years 2001 and 2005 was $198,412 and $952,380, respectively; and nil doe 2002, 2003 and 2004. ... Furthermore … the amount of Holdco's GRIP is $400,000, since it seems reasonable to us to consider, in this situation, that the $400,000 dividend that Holdco received from Opco during 2001 is attributable to an amount described in Element A of the GRIP formula in respect of Opco. ...

During each of 2001 to 2005, ABCco had full rate taxable income ("FRTI") of $160,000. ... (a) and (b) of A in the GTIP addition formula for 2001 to 2005 for ABCco was $504,000. ... The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

4 June 2014 External T.I. 2013-0513761E5- Meaning of "cost" in determining "equity amount"-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Equity Amount- Paragraph (c) "cost" not reduced by amortization Generally, … the "cost" of property …include[s] the amount laid down to acquire such property. … The Queen v. Canada Trustco Mortgage Company (2005 DTC 5523),…stated…that ‘[t]extually, the CCA provisions use ‘cost' in the well-established sense of the amount paid to acquire the assets….'…[T]he term "cost" for the purposes of the definition of "equity amount" in subsection 18(5)… means the original acquisition cost of a property. ...

11 October 2017 External T.I. 2016-0673171E5- Foreign tax credit- former resident-- summary under Subsection 126(2.21) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2.21) emigration-year return generally cannot be opened up more than 6 years later to allow a FTC for foreign tax imposed on a subsequent sale A Korean individual became a resident of Canada in 2005 while owning Korean real property that had previously been purchased $600,000 and that had a fair market value of $1,000,000. ... …The Minister is not obligated to reassess a return simply because a waiver is filed by a taxpayer for a particular taxation year …. [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. … … 2016-066042 … opined that if any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) of the Act, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

CRA stated: [A]ssuming that after the acquisition of the shares, Subco would be merged with OPCO by way of an amalgamation or winding-up, we note that the Given Situation would be similar to the example given in paragraph 4 of Supplement 1 … IC 88-2. The CRA's position is generally not to apply subsection 245(2) in situations similar or identical to [such] example …. However, if Subco were not merged with OPCO following the acquisition of the shares, other elements may have to be considered …. ...

16 November 2006 External T.I. 2006-0203131E5 F- Régime à traitement différé-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) advances received were salary rather than loans and, when repaid, reduced employment income An employee signed a deferred salary leave contract for the period from June 29, 2002, to December 29, 2006, with his leave being taken from May 14 to November 11, 2005. ... Such prepaid salary (i.e., the amounts received while on leave) were required to be included in the employee's income for the year in which it was paid, i.e., the 2005 taxation year. However, in the year of resignation, i.e. 2006, since the salary for the last two pay periods was withheld to recover part of the prepaid salary, the amount of salary received by the employee- net of the deductions made by the employer – was to be included in the employee's income for 2006 In addition, any cheques written by the employee in 2006 for prepaid salary reimbursements would reduce his employment income for 2006 and, if repaid in 2007, would reduce the employee's 2006 employment income, so that the employer would be required to file an amended T4 slip for that taxation year. ...