Search - 2005年 抽纸品牌 质量排名

8 February 2005 Internal T.I. 2004-0099681I7 F- Remboursement de frais de déménagement-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursement of reasonable living expenses incurred until the employee permanently occupies new home in employer’s area is not a benefit A new employee previously living more than 40 kilometres from the employer’s plant was paid a daily allowance of $50 per day for 28 days, to cover room and board, until the employee's housing was secured. The Directorate stated: T]he CRA does not consider the reimbursement of reasonable living expenses incurred until the employee permanently occupies the employee’s new home to be a reimbursement of personal expenses. … [T]he 2004-2005 T4130 no longer states that reasonable living expenses are limited to a maximum of 15 days. ...

28 October 2005 External T.I. 2005-0145891E5 F- Redemption of Shares- Balance of Purchase Price-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) amount of deemed dividend arose on redemption date based on amount of covenanted future redemption payments On January 1, 2005, Canco purchases for cancellation 100 common shares, having a fair market value of $100,000, in consideration for paying $25,000 per annum during the four following years to the redeemed shareholder (“Shareholder”). As a legal matter, the 100 shares were cancelled on January 1, 2005 and, thereafter, the Shareholder held a debt claim of $100,000. ... CRA responded: … [T]he amount of the deemed dividend at the time of the purchase for cancellation of the shares of the capital stock of Canco on January 1, 2005 would be equal to the value of any consideration given by Canco and received by the Shareholder for the Shareholder’s shares of the capital stock of Canco at the time of the purchase for cancellation of such shares, including any covenants or promises to pay amounts in the future, that would be in excess of the paid-up capital in respect of such shares. ...

6 May 2005 External T.I. 2005-0116981E5 F- Rollover under section 85 of an ECP-- summary under Paragraph 14(1)(a) Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(1)- Paragraph 14(1)(a) “exempt gains balance" is of no utility in calculating the amount to be included in income under … 14(1)(a)" Mr. ... In 2005, he transferred his business to a wholly-owned corporation under s. 85. ... X's income for 2005 under paragraph 14(1)(a) because Mr. X has already claimed deductions in respect of the Goodwill pursuant to paragraph 20(1)(b).” ...

14 May 2005 Internal T.I. 2008-0304841I7- Interest deductibility-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) interest not deductible after CCAA stay "CanOpco" is a 100% subsidiary of "NRHoldco,” a US based corporation, which filed for protection under Chapter 11 of the U.S. ... CRA responded negatively, stating: []I]n Re Philip's Manufacturing Ltd. (1992), 12 C.B.R. (3d) 133 (B.C.S.C.), add'l reasons in (1992), 91 D.L.R. (4th) 766 (B.C.S.C.) aff'd in (1992), 12 C.B.R. (3d) 149 (B.C.C.A.), it was held that, since the purpose of the stay of proceedings under the CCAA was to maintain the status quo, no interest was payable on claims during the period of the stay without a court order. … CanOpco's legal obligation to pay interest expired on the day it obtained protection from its creditors under the CCAA. ...

7 April 2005 External T.I. 2004-0099191E5 F- Inventaire d'un artiste-- summary under Subsection 70(2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(2) application of s. 70(2) or (3) to artist’s inventory After noting that the inventory of an artist that is valued at nil pursuant to s. 10(6) is a right or thing, CRA indicated that, subject to s. 70(3), the value of the inventory is included in the deceased’s terminal return unless the legal representative elects under s. 70(2) to file a separate return for the year of death. ... Where s. 70(3) applies, the value of the deceased's rights or property will instead be included in computing the income of the beneficiary for the taxation year in which the beneficiary received it, and the beneficiary’s cost will be determined under s. 69(1.1) to equal the total of the part of the cost thereof to the deceased as had not been deducted by the deceased in computing the deceased’s income for any year, and any expenditures made or incurred by the beneficiary to acquire the property – which cost will be used to compute the beneficiary's income when the inventory is sold. ...

18 March 2005 External T.I. 2005-0117691E5 F- Significant increase in interest in any corp-- summary under Subparagraph 55(3)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a)- Subparagraph 55(3)(a)(ii) preliminary transfer of Opco shares to Holdco preliminary to a spin-off engaged the s. 55(3)(a)(ii) exclusion Two brothers (X and Y) each hold half the shares of Opco which, in turn, holds 35% of the shares (being common shares) of Subco. ... Y) who were unrelated persons immediately before the particular time …. ...