Search - considered

(c) of variable A of the formula, for its 2004 taxation year, CRA stated: [S]ince DEFco received from ABCco, during the period 2001 to 2005, a portion ($800,000) of the total taxable dividends paid by ABCco ($900,000), the portion of the dividend received by DEFco that can reasonably be considered to be attributable to an amount described in paragraph (a), (b) or (c) of the description of A in respect of ABCco should be prorated based on the taxable dividends received by DEFco out of the total taxable dividends paid by ABCco. ...

Is the income earned in the executor’s year considered as not payable to beneficiaries, and does this depend on whether the estate fiscal year falls entirely within the executors’ year? ...

These factors should be considered in light of the purpose of section 84.1, which is to prevent the withdrawal of corporate surpluses as a tax-free return of capital by way of a non-arm's length transfer of shares and through the use of the capital gains deduction. ...

For the purposes of Part XIII withholding and section 116, any amount paid or credited by a payer to the Canadian Sub-custodian in respect of the property held by the Subfund on behalf of the Pension Fund, including purchase consideration for such property, will be considered an amount paid or credited to the Pension Fund in proportion to its participation in the assets and income of the particular Subfund. ...

29 January 2018 External T.I. 2017-0682301E5- Deemed Distribution and Withdrawal from IRA-- summary under Clause 56(1)(a)(i)(C.1) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(i)- Clause 56(1)(a)(i)(C.1) the deemed U.S. income inclusion from an IRA on renouncing U.S. citizenship or relinquishing a green card also is recognized for ITA purposes The Taxpayer, a Canadian citizen, was considered under the Code to be a U.S. long term resident and to have received a taxable distribution of her entire interest in her IRA the day before she relinquished her green card. ...

Rulings The reallocation of the properties in Fund 1 to Fund 2 will result in Fund 1 ceasing to exist and Fund 2 as continuing to exist for s. 138.1(1)(a) purposes and be considered to be a transfer by Trust 1 of all of its property to Trust 2 for the purpose of s. 107.4, with s. 107.4(3)(j) applying to deem each of the Fund 1 Policyholders to have disposed of their capital interests in Trust 1 for proceeds equal to the cost amount of such capital interests immediately before the disposition and to have acquired capital interests in Trust 2 at a cost equal to the amount determined by subparagraph 107.4(3)(j)(ii). ...

B considered to have received a designated benefit by virtue of her being alive at the time of the formation of the estate on the death of Mr. ...

Rulings No portion of the cash or near cash investments distributed by Opco to Holdco, or by Holdco to Parent, will be considered to be subject property of an RCA for the purposes s. 207.6(1), or a “contribution” made to an RCA, in respect of the SERP Obligations that will be assumed by Parent. ...

CCRA indicated that although s. 40(3.4) would apply, under its administrative position, only 1/2 of the taxpayer's loss would be considered to be nil under s. 40(3.4)(a) under the formula: Deemed nil loss = (the lesser of S, P and B) / S x L where S = the number of shares disposed of at that time 100 P = the number of shares acquired during the period described in paragraph 40(3.3)(b) 50 B = the number of shares remaining at the end of that period 50 L = the loss on the disposition otherwise determined And therefore: Deemed nil loss = 50 / 100 x L CCRA indicated that s. 40(3.4) would apply to the entire loss arising under a second variation, under which, on June 1, 200X, the taxpayer disposed of 50 of the 100 Pubco common shares and on June 2, 200X, acquired an additional 50 Pubco common shares of Pubco. ...

Can the minor child be considered, in these Scenarios, to have sole beneficial interest in the amounts payable under the annuity as required by s. 60(l)(ii)(B) as it was proposed to be amended [which stipulated that the annuity be one "under which the taxpayer, or a trust under which the taxpayer is the sole person beneficially interested in amounts payable under the annuity, is the annuitant …"]? ...