Search - 2005年 抽纸品牌 质量排名

24 January 2005 External T.I. 2004-0099471E5 F- Convention de retraite pour un actionnaire-employé-- summary under Paragraph 56(1)(x) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(x) Part XI.3 tax and s. 56(1)(x) income inclusion apply even where RCA contribution is partially or fully non-deductible Are contributions by a corporation to an RCA deductible in computing its income where the contributions relate to services rendered by a shareholder-employee while self-employed and before the corporation’s incorporation, and can the RCA be funded when such contributions are not deductible to the employer? After paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not … restrict the contributions necessary to fund an RCA. ...

3 February 2005 External T.I. 2005-0112141E5 F- Safe income-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income prorated on a partial crystallization of an accrued gain Mr. A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...

2 February 2005 External T.I. 2004-0104671E5 F- Convention de retraite- Fonds mis de côté-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement no requirement that payment to the other be in trust In a general response to a query as to whether a special reserve fund that an employer creates by depositing money with a broker to provide for the payment of a portion of a pension payable for the retirement of a management employee will constitute a salary deferral arrangement or a retirement compensation arrangement, CRA stated: In a situation where an employer pays money to a bank, trust company or broker to meet its obligations upon the retirement of an employee, the money could be considered a contribution in respect of benefits that may be received by a person upon that person's retirement. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

23 February 2005 External T.I. 2004-0093921E5 F- Déménagement d'un employé-Paiement de frais-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of house-hunting fee for new hire was non-taxable The corporation hired someone to search for accommodation in Canada of its new president, who was moving to Canada to take up his position, and to take care of the administrative formalities of obtaining a health insurance card, a social insurance number, a driver's licence and opening a bank account. ... Similarly, it is necessary for the president to have a social insurance number in order to be employed in Canada. … While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...

28 February 2005 Internal T.I. 2004-0103991I7 F- Remboursement de frais de scolarité-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of tuition fees conditional on a return to extended employment was not a taxable benefit The taxpayer, who had been employed as a temporary lecturer at a University Department, was hired to work as a professor at the Department upon her completion of doctoral studies at a US university and was paid by the Department various of the expenses incurred by her in connection with such studies including the tuition fees of the US university. ... Furthermore, the Taxpayer was to return to the Employer's employ for a period at least as long as the number of years she had pursued her doctoral studies and on the date of her submission … she was still employed by the Employer. ...

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Subsection 207.5(2) Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ... After indicating that the RCA trust could not recover the refundable tax in respect of the contribution used to pay the costs of issuing a letter of credit when paying such pension benefits to the beneficiaries, CRA stated: A custodian of an RCA may make an election under subsection 207.5(2) to recover refundable tax where the specified property of the RCA (other than the right to claim a refund under Part XI.3) at the end of the year consists solely of cash, debt obligations or shares listed on a prescribed stock exchange. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...