Search - 2005年四川高考重本线

2 February 2005 Internal T.I. 2005-0111961I7 F- Reassessment of a Partner-- summary under Subsection 152(1.4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.4) CRA can assess a partner directly to change the partnership income allocable to it rather than being required to make a partnership-level determination under s. 152(1.4) The latest date by which the Minister could make a determination at the level of a limited partnership (BCOM) for its 2001 fiscal year pursuant to s. 152(1.4) was February 28, 2005, whereas the normal reassessment period for its general partner (XCO) for its taxation year in which the BCOM's 2001 fiscal period ended (the "Particular Taxation Year"), would expire on April 25, 2005. ...

9 November 2005 Internal T.I. 2005-0133261I7 F- Frais médicaux payés à l'avance-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) prepaid dental care does not qualify until the year in which the care is received In finding that dental care that was prepaid by the individual would not qualify for the credit until the care occurred, CRA stated: In a situation where an individual enters into an agreement with a dentist to pay for dental services on a monthly basis, the amounts paid for these services will qualify as a medical expense provided that the monthly payments are made within the same 12-month period in which the services were rendered. In the above scenario, the individual will not be able to include the prepayments in the tax credit calculation for the 2004 taxation year because the expenses were not incurred until 2005. ...

11 February 2005 Internal T.I. 2005-011284-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Damages received from the Department of Fisheries and Oceans in respect of the denial of a supplementary fishing licence were received on income account. ...

13 January 2005 Internal T.I. 2004-0103291I7- NRO penalty for failure to file-- summary under Subsection 162(2.1) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(2.1) "The unambiguous language of subsection 162(2.1) clearly indicates that it will apply to all non-resident corporations under an obligation to file a return pursuant to either of subparagraphs 150(1)(a)(i) and (ii), including non-resident corporations that carry on business in Canada during the year or that dispose of taxable Canadian property. ...

14 January 2005 Internal T.I. 2004-009814-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) assumption in consideration for debt forgiveness The interest on debt previously owing by the taxpayer's shareholder that the taxpayer assumed in consideration for the forgiveness of a non-interesting bearing loan that had been owing by it to the shareholder and which had resulted from the transfer, in a prior year, of public shares from the shareholder to the taxpayer was non-deductible given that such assumed debt would not represent borrowed money and the forgiveness of the debt would not result in the acquisition of property. ...

29 March 2005 Internal T.I. 2005-0111401I7 F- Article 7306 du Règlement-- summary under Regulation 7306 Summary Under Tax Topics- Income Tax Regulations- Regulation 7306 referenced taxation year is the individual's calendar year Do the terms "taxation year" and "in the year" refer to the individual's taxation year, i.e., calendar year, or to the taxation year of the employer. ...

4 May 2005 Internal T.I. 2005-0121761I7 F- Déduction des intérêts- améliorations locatives-- summary under Paragraph 18(3.1)(a) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(3.1)- Paragraph 18(3.1)(a) s. 18(3.1) generally inapplicable to borrowing by tenant to make leasehold improvements In order to expand his bookshop, the taxpayer rented larger premises and undertook renovations before fitting them out, and continued to carry on his business in the current premises during the renovation period. ...

25 April 2005 Internal T.I. 2004-0108301I7 F- Coût d'une automobile-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) each car lease payment contained an embedded premium referable to the bargain purchase option, which was added under s. 49(3) The cost (for purposes of C of the standby charge formula under s. 6(2)) of an automobile acquired by the employer at the end of its lease pursuant to exercise of bargain purchase option was increased under s. 49(3) by the portion of each preceding lease payment that was to be reasonably treated as an option premium, i.e., that “could be considered as a payment in respect of the right to purchase the property in the future.” ...

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. ...

13 April 2005 Internal T.I. 2004-0109071I7 F- Partie XIII et revenus locatifs-- summary under Subsection 215(3) Summary Under Tax Topics- Income Tax Act- Section 215- Subsection 215(3) property manager required to withhold on the gross rents collected absent a s. 216(4) election A property manager agreed with the owners of condos, including the non-resident owner in question, to rent out the condo on behalf of the owner, and pay the rents collected by it net of expenses to the owner. ...