Search - connection
Results 3821 - 3830 of 7791 for connection
Ruling
2019 Ruling 2019-0795521R3 - XXXXXXXXXX split-up butterfly
We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the issues described herein are: (a) in a previously filed tax return of the Taxpayers or person related to the Taxpayers; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; (c) under objection by the Taxpayers or a person related to the Taxpayers; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ... The agreed amount in respect of each such eligible property will be as follows: a. in the case of capital property (other than depreciable property of a prescribed class), an amount equal to the lesser of the amounts described in subparagraphs 85(1)(c.1)(i) and (ii); b. in the case of depreciable property of a prescribed class, if any, an amount not less than the least of the amounts described in subparagraphs 85(1)(e)(i), (ii) and (iii); and c. in the case of inventory owned in connection with the XXXXXXXXXX business of DC, an amount determined in accordance with the formula set out in paragraph 85(1)(c.2). ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...
Ruling
2019 Ruling 2019-0811641R3 - Multi-wing split up butterfly
In connection with the winding-up, the TC Sub1 Redemption Note will be assumed by TC1, the TC Sub2 Redemption Note will be assumed by TC2 and the TC Sub3 Redemption Note will be assumed by TC3. 29. ... In connection with the winding-up of DC, DC will distribute all of its assets, which will consist only of TC Sub1 Redemption Note, TC Sub2 Redemption Note and the TC Sub3 Redemption Note and the rights to any tax refunds referred to in Paragraph 34, to TC1, TC2 and TC3, as the case may be, in accordance with their respective shareholdings. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover Yours truly, XXXXXXXXXX For Division Director Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
5 June 1990 Ruling 90M06451 F - 1990 Round Table Questions
Answer In determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. ... Is it the government's intention to force all related companies, regardless of their inter-connection of business interests, to come to an agreement on how to allocate the capital deduction, or is it possible that a more reasonable middle ground could be reached by ensuring all associated corporations must allocate the deduction? ... The Queen 83 DTC 5041, when he described the expression as "probably the widest of any expression intended to convey some connection between two related subject matters". ...
Miscellaneous severed letter
5 June 1990 Income Tax Severed Letter ACC9598 - 1990 Round Table Questions
Answer In determining whether a property is a tax shelter for the purposes of section 237.1 of the Act, the calculation of deductible losses and other deductible amounts is to be made on a prospective basis based upon statements or representations made or proposed to be made in connection with that property. ... Is it the government's intention to force all related companies, regardless of, their inter-connection of business interests, to come to an agreement on how to allocate the capital deduction, or is it possible that a more reasonable middle ground could be reached by ensuring all associated corporations must allocate the deduction? ... The Queen [[1983] C.T.C. 20] 83 DTC 5041, when he described the expression as "probably the widest of any expression intended to convey some connection between two related subject matters". ...
Ruling
2022 Ruling 2021-0920791R3 - Butterfly Reorganization
To the best of your knowledge and that of the Taxpayers involved, none of the Proposed Transactions (as defined below) or the issues involved in this Ruling request are the same as or substantially similar to transactions or issues that are: (i) in a previously filed tax return of any of the Taxpayers or a related person and: A. being considered by the CRA in connection with such return; B. under objection by any of the Taxpayers or a related person; or C. the subject of a current or completed court process involving any of the Taxpayers or a related person; or (ii) the subject of a Ruling request previously considered by the Income Tax Rulings Directorate. ... All properties of TC Sub1 and TC Sub2 will be distributed and all liabilities of TC Sub1 and TC Sub2, if any, will be either discharged or assumed by its TC. ln connection with the winding-up, the TC Sub1 Redemption Note will be assumed by TC1 and the TC Sub2 Redemption Note will be assumed by TC2. 42. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...
GST/HST Interpretation
16 February 1994 GST/HST Interpretation 11585-13[1] - Application of ETA 141(5)(c), 141.01 and 141.1
It also requires, where appropriate, pro-rating of inputs for input tax credit purposes in connection with the acquisition, establishment, disposition or termination of a commercial activity. ... The activities listed under (b) above are in connection with the termination of a commercial activity and therefore are part of the commercial activity. ... (a) Could a company voluntarily register for GST effective January 1, 1991 if its only activities are in connection with the termination of its commercial activities as described in paragraph 141(5)(c)? ...
Old website (cra-arc.gc.ca)
Costs that Fall within the Scope of Subsection 183(2)
Therefore, anything related to taking possession of property would be in connection with the seizure or repossession. ... It is the Department's view that the lawyers' services were acquired in connection with the seizure of the property. ... It is the Department's view that the appraiser's fees were acquired in connection with the seizure of the property. ...
Old website (cra-arc.gc.ca)
Newsletters for charities - Numerical index
Newsletter Issue Topics Included Charities Connection No. 12 Budget 2012- Changes affecting charities and other qualified donees Charity Quick View and your charity Charities Information Sessions and Webinars: New Schedule Registered Charity Basic Information Sheet Good feedback leads to better advice Guidance Products: Fundraising guidance update; Helping you understand the rules; Your opinion counts Charities Connection No. 11 Special Edition: Budget 2011- Changes for charities, registered Canadian amateur athletic associations, and qualified donees Charities Connection No. 10 The season of giving – Things to remember when issuing official donation receipts Outreach activities Reminder to file your Form T3010, Registered Charity Information Return Charities Connection No. 9 The Canada Not-for-Profit Corporations Act- Now in Force Charities Connection No. 8 Keep your eye on the ball East Africa Drought Relief Fund Prime Minister's Voluntary Awards- Update Charities Connection No. 7 Budget 2011 Education and training for charity volunteers Charities and giving webpage update New guidance on using an intermediary to carry out a charity's activities in Canada Reminder to file your Form T3010, Registered Charity Information Return Prime Minister's Volunteer Awards Charities Connection No. 6 Filing a complete T3010, Registered Charity Information Return New reference numbers for guidance products Hosting information sessions for charities Standard for registered charities Charities Connection No. 5 The new Form T3010-1, Registered Charity Information Return The Charities Directorate's guidance documents Giving to charity: Information for donors- Speaker's kit Charities Connection No. 4 Facts and figures on the work of the Charities Directorate in 2009-2010 Education and training for charities Education for donors New webpages: Revoking registered status Charities Connection No. 3 Service Clubs and Fraternal Societies Changes to webpage addresses (URLs) Are you HST ready? Increasing text size on our webpages Reminders Charities Connection No. 2 Payroll and Income Taxes Changes to Charities Information Sessions and Webinars Update: Budget 2010- Changes for charities Reminders Charities Connection No. 1 From the Director General Budget 2010- Changes for charities Operating within the scope of a charity's objects Changes to policy-related products Filing a complete information return National Volunteer Week Reminders Newsletter No. 33 From the Director General Improper receipting New fundraising guidance Many charities-related forms are now saveable My Business Account for Charities Small and Rural Charities (SARC) Initiative update Charities Webinars Charities Partnership and Outreach Program update Tax shelter-related revocations Guide RC4108 is no longer available Obligation to file financial statements Reminder to file Form T2081 International Volunteer Day Newsletter No. 32 Appeals Branch- new address Charities Information Sessions Contact Information Corporate status- Obligation to maintain Electronic Mailing List Financial statements- filing Form T2050 (08), Application to Register a Charity Under the Income Tax Act Form T3010B (09), Registered Charity Information Return Improve your application- avoid unnecessary delays Small and rural charities initiative Webinars Newsletter No. 31 Facts and figures Form T2050, Application to Register a Charity Under the Income Tax Act Guide T4063, Registering a Charity for Income Tax Purposes Charities incorporated in Ontario Charities Partnership and Outreach Program Policies- new and upcoming Public education update Small and rural charities initiative Model objects Court news Disaster relief Do Not Call List (DNCL) Electronic mailing list (EML) Charities Information Sessions Guide T4033, Completing the Registered Charity Information Return Compliance- Top 3 Disbursement quota Receipting- no receipting on behalf of another organization- split receipting Registration Numbers- no lending Questions and answers- Correcting errors and making changes Processing returns- delay avoidance Form T3010B (09), Registered Charity Information Return Newsletter No. 30 Small and rural charities initiative Website Charities Checklists Proposed policy on fundraising Charitable Work and Ethnocultural Groups: Information on registering as a charity Partnership and Outreach Program Telephone enquiries service standard Electronic Mailing List (EML) Charities Information Sessions (formerly the Roadshow) Guide T4033, Completing the Registered Charity Information Return Excess Corporate Holdings Worksheet for private foundations T3010B, Registered Charity Information Return T2050, Application to Register a Charity Under the Income Tax Act Newsletter No. 29 40th anniversary of registering charities Electronic mailing list (EML) Guide T4033, Completing the Registered Charity Information Return Charities Information Sessions (formerly the Roadshow) Court news A.Y.S.A. ...
Current CRA website
Newsletters for charities - Numerical index
Newsletter Issue Topics Included Charities Connection No. 12 Budget 2012- Changes affecting charities and other qualified donees Charity Quick View and your charity Charities Information Sessions and Webinars: New Schedule Registered Charity Basic Information Sheet Good feedback leads to better advice Guidance Products: Fundraising guidance update; Helping you understand the rules; Your opinion counts Charities Connection No. 11 Special Edition: Budget 2011- Changes for charities, registered Canadian amateur athletic associations, and qualified donees Charities Connection No. 10 The season of giving – Things to remember when issuing official donation receipts Outreach activities Reminder to file your Form T3010, Registered Charity Information Return Charities Connection No. 9 The Canada Not-for-Profit Corporations Act- Now in Force Charities Connection No. 8 Keep your eye on the ball East Africa Drought Relief Fund Prime Minister's Voluntary Awards- Update Charities Connection No. 7 Budget 2011 Education and training for charity volunteers Charities and giving webpage update New guidance on using an intermediary to carry out a charity's activities in Canada Reminder to file your Form T3010, Registered Charity Information Return Prime Minister's Volunteer Awards Charities Connection No. 6 Filing a complete T3010, Registered Charity Information Return New reference numbers for guidance products Hosting information sessions for charities Standard for registered charities Charities Connection No. 5 The new Form T3010-1, Registered Charity Information Return The Charities Directorate's guidance documents Giving to charity: Information for donors- Speaker's kit Charities Connection No. 4 Facts and figures on the work of the Charities Directorate in 2009-2010 Education and training for charities Education for donors New webpages: Revoking registered status Charities Connection No. 3 Service Clubs and Fraternal Societies Changes to webpage addresses (URLs) Are you HST ready? Increasing text size on our webpages Reminders Charities Connection No. 2 Payroll and Income Taxes Changes to Charities Information Sessions and Webinars Update: Budget 2010- Changes for charities Reminders Charities Connection No. 1 From the Director General Budget 2010- Changes for charities Operating within the scope of a charity's objects Changes to policy-related products Filing a complete information return National Volunteer Week Reminders Newsletter No. 33 From the Director General Improper receipting New fundraising guidance Many charities-related forms are now saveable My Business Account for Charities Small and Rural Charities (SARC) Initiative update Charities Webinars Charities Partnership and Outreach Program update Tax shelter-related revocations Guide RC4108 is no longer available Obligation to file financial statements Reminder to file Form T2081 International Volunteer Day Newsletter No. 32 Appeals Branch- new address Charities Information Sessions Contact Information Corporate status- Obligation to maintain Electronic Mailing List Financial statements- filing Form T2050 (08), Application to Register a Charity Under the Income Tax Act Form T3010B (09), Registered Charity Information Return Improve your application- avoid unnecessary delays Small and rural charities initiative Webinars Newsletter No. 31 Facts and figures Form T2050, Application to Register a Charity Under the Income Tax Act Guide T4063, Registering a Charity for Income Tax Purposes Charities incorporated in Ontario Charities Partnership and Outreach Program Policies- new and upcoming Public education update Small and rural charities initiative Model objects Court news Disaster relief Do Not Call List (DNCL) Electronic mailing list (EML) Charities Information Sessions Guide T4033, Completing the Registered Charity Information Return Compliance- Top 3 Disbursement quota Receipting- no receipting on behalf of another organization- split receipting Registration Numbers- no lending Questions and answers- Correcting errors and making changes Processing returns- delay avoidance Form T3010B (09), Registered Charity Information Return Newsletter No. 30 Small and rural charities initiative Website Charities Checklists Proposed policy on fundraising Charitable Work and Ethnocultural Groups: Information on registering as a charity Partnership and Outreach Program Telephone enquiries service standard Electronic Mailing List (EML) Charities Information Sessions (formerly the Roadshow) Guide T4033, Completing the Registered Charity Information Return Excess Corporate Holdings Worksheet for private foundations T3010B, Registered Charity Information Return T2050, Application to Register a Charity Under the Income Tax Act Newsletter No. 29 40th anniversary of registering charities Electronic mailing list (EML) Guide T4033, Completing the Registered Charity Information Return Charities Information Sessions (formerly the Roadshow) Court news A.Y.S.A. ...
Current CRA website
Costs that Fall within the Scope of Subsection 183(2)
Therefore, anything related to taking possession of property would be in connection with the seizure or repossession. ... It is the Department's view that the lawyers' services were acquired in connection with the seizure of the property. ... It is the Department's view that the appraiser's fees were acquired in connection with the seizure of the property. ...