Search - connection

Results 1311 - 1320 of 15547 for connection

CRA publishes the final version of its 2018 CTF Roundtable answers

Exception Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares investment business a business for excluded share purposes Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Amount- Paragraph (e)- Subparagraph (e)(i) “derivation” for TOSI purposes of dividends from previously earned income from a related business 27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 27 November 2018 CTF Roundtable Q. 11, 2018-0779971C6- Record Retention Policy Guideline Income Tax Act- Section 232- Subsection 232(1)- Solicitor-Client Privilege solicitor-client privilege does not extend to list of uncertain tax positions Income Tax Act- Section 231.1- Subsection 231.1(1) in some circumstances CRA considers that it can require a taxpayer to disclose its uncertain tax positions 27 November 2018 CTF Roundtable Q. 12, 2018-0785021C6- Investment management fees 27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible 27 November 2018 CTF Roundtable Q. 14, 2018-0779911C6- Foreign exchange Income Tax Act- Section 20- Subsection 20(14) accrued interest translated on transfer date Income Tax Act- Section 261- Subsection 261(2)- Paragraph 261(2)(b) accrued interest under both ss. 20(14)(a) and (b) is translated at the transfer date spot rate 27 November 2018 CTF Roundtable Q. 15, 2018-0780011C6- Class 14.1 Income Tax Act- Section 13- Subsection 13(35)- Paragraph 13(35)(a) capital expenditures not giving rise to property are deemed to be goodwill property Income Tax Regulations- Schedules- Schedule II- Class 14.1 Class 14.1 “property” need not be property 27 November 2018 CTF Roundtable Q. 16, 2018-0780031C6- 2018 CTF- Q16- Passive Income Reduction Rules Income Tax Act- Section 125- Subsection 125(5.1)- Paragraph 125(5.1)(b) effective date of the passive income rules for non-calendar year associated corporations ...

The Joint Committee explains why the sledgehammer approach of Finance to encouraging compliance with requirements for information is unconstitutional

To illustrate the disproportionate nature of the automatic penalty under s. 231.7(6), consider a corporation which provided 95 out of 100 documents requested regarding an audit of three taxation years, and claimed solicitor-client privilege for the other 5 documents and, in connection with CRA seeking a compliance order, the Federal Court determines that there was insufficient evidence to establish that two of the documents were privileged: even though the corporation was substantially compliant, it is subjected to the penalty of 10% of its tax for the three years. ...

2007 Ruling 2007-0257241R3 - XXXXXXXXXX Ruling

To the best of your knowledge and that of the taxpayer or a related person involved, none of the issues involved with this request: (i) is being considered by a tax services office or a taxation centre in connection with a tax return already filed by the taxpayer or a related person; (ii) is under objection; or (iii) is before the courts or, if a judgement has been issued, the time limit for appeal has not expired. ... Rulings Previously Issued by CRA in connection with Gco Project 19. Zco received the Tax Rulings XXXXXXXXXX. ... Subsections 17(1) and 17(2) will not apply to Zco to impute an income inclusion in connection with the New G Act Loan made by US LLC to G.I.E. ...

S4-F8-C1 - Business Investment Losses

The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor. ... For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163, 2005 DTC 5281). ... Therefore, in connection with the disposition of the debt, Mr. R’s 2015 tax return will also reflect an allowable capital loss in the amount of $60,000 ($120,000 x ½). 1.65 The reduction under subparagraph 39(1)(c)(viii) in the case of a disposition by a trust of a share or a debt in an SBC is the amount determined under subsection 39(10). ...

18 February 1998 Internal T.I. 9712976 - PERMANENT ESTABLISHMENT - MANAGEMENT CONSULTING COMPANY

Insufficiency of Mere Human Connection Paragraph 5 of Article V of the Convention is a deeming rule which, with certain exceptions, deems a person acting in Canada on behalf of a U.S. resident to be a permanent establishment in Canada if such person has, and habitually exercises in Canada, an authority to conclude contracts in the name of the U.S. resident. ... The facts of the case are that a Swedish company was hired as a consultant for an estimated time of 15 months in connection with the hook-up of a drilling platform on the Norwegian continental shelf. ... However, it is necessary to gather additional facts in order to establish a connection between contracts of short duration (e.g. 2 months) in order to demonstrate that they, together with all other contracts, comprise business conducted in Canada through a permanent establishment. ...

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs

Definition of advantage 3.5 An advantage in relation to a registered plan is defined in subsection 207.01(1) as any of the following: certain benefits or debt that are conditional on the existence of the plan, subject to listed exceptions (see ¶3.6 to 3.15) an increase in the FMV of the property held in connection with the plan which increase is reasonably attributable to certain transactions or amounts (see ¶ 3.16 to 3.26) income or a capital gain that is reasonably attributable to certain property or transactions in respect of the plan (see ¶ 3.28 to 3.31) a registered plan strip in respect of the plan (see ¶ 3.32 to 3.34) Conditional on plan 3.6 Paragraph (a) of the definition of advantage includes any benefit, loan or indebtedness that is conditional in any way on the existence of the registered plan, subject to certain enumerated exceptions discussed in ¶3.7 to 3.12. ... That is, the advantage tax will nonetheless apply in respect of any future increases in the total FMV of the property held in connection with the plan that are reasonably attributable, directly or indirectly, to the swap transaction. ... Settlement payments 3.42.1 Occasionally, payments may be made to settle a class-action lawsuit or other legal proceeding in respect of actionable losses incurred in connection with assets of registered plans. ...

S4-F3-C2 - Provincial Income Allocation

Amounts excluded from gross revenue 2.23 Subsection 402(5) of the Regulations provides that for purposes of subsection 402(3), gross revenue of a corporation does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations. 2.24 In Provincial Income Allocation Newsletter No. 1 the CRA confirmed that a broad interpretation of the excluded amounts is appropriate for the purposes of Part IV of the Regulations. Under such a broad interpretation, interest on promissory and other notes, bankers’ acceptances, intercompany loans, certificates, guaranteed investment certificates, and any unsecured debt instruments or other similar obligations would also be excluded from the gross revenue of a corporation. 2.25 In addition, the reference in subsection 402(5) to “that is not used in connection with the principal business operations of the corporation” refers only to “rentals or royalties from property” and not to the other items enumerated in that subsection. 2.26 Examples of amounts that would normally be excluded in determining gross revenue of a corporation for purposes of Part IV of the Regulations include the following: Amounts received or receivable in respect of expenditures incurred by the corporation. ... Other factors that are relevant in determining whether an individual is an employee of a permanent establishment of any particular province include the following: whether the individual is also considered to be an employee of that establishment for provincial government related filing requirements (for example, income tax deduction, medical premium deduction, etc.); whether the employee maintains an office or other connections in that establishment; and whether the employee normally reports to or receives instructions from that establishment. 2.61 Under paragraph 413(1)(a) of the Regulations, where a corporation is not resident in Canada, “salaries and wages paid in a year” does not include salaries and wages paid to employees of a permanent establishment outside Canada. ...

S1-F3-C2 - Principal Residence

X lived in the residence from October 15, 2007 until he disposed of the property on December 1, 2011 for $250,000, incurring no costs in connection with the disposition. ... Form T2062, Request by a Non-Resident of Canada for a Certificate of Compliance Related to the Disposition of Taxable Canadian Property, or a similar notification, must be filed in connection with a request for a section 116 certificate. ... It has been assumed in these examples that, on each actual disposition, no costs were incurred in connection with that disposition. ...

S1-F1-C3 - Disability Supports Deduction

Where the taxpayer has a perceptual disability, the cost of talking textbooks used by the taxpayer in connection with the taxpayer's enrolment at a secondary school in Canada or at a designated educational institution is an eligible expense, provided that a medical practitioner has certified in writing, that the taxpayer is a person who, because of that disability, requires those textbooks. ... This requirement remains if the attendant is resident in Canada for tax purposes. 3.10 Therefore, if a taxpayer who is resident in Canada for tax purposes has a perceptual disability and incurs the cost of a talking textbook used in connection with the taxpayer’s enrolment at a secondary school located outside of Canada or, if the taxpayer is a person with a disability who incurs the cost of attendant care provided outside Canada, the costs incurred will be eligible for the disability supports deduction assuming all the other requirements of section 64 (as discussed in ¶ 3.1 to 3.8) are met. ...

S2-F1-C2 - Retiring Allowances

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...

You are here