Search - convention
Results 4761 - 4770 of 5494 for convention
Ruling
1998 Ruling 9825343 - FOREIGN AFFILIATE REORGANIZATION
Income Tax Convention (the "U.S. Treaty"). More particularly, each of U.S. ...
Ruling
1999 Ruling 9833743 - SHARES SUBSTITUTED FOR OTHER SHARES
Income Tax Convention [the "Treaty"]). d) "NV" means XXXXXXXXXX. e) "T" means XXXXXXXXXX. f) "U" means XXXXXXXXXX. g) "V" means XXXXXXXXXX. h) "W" means XXXXXXXXXX. i) "X" means XXXXXXXXXX. j) "USOLDCO" means XXXXXXXXXX. k) "CANOLDCO" means XXXXXXXXXX. ...
Miscellaneous severed letter
7 July 2007 Income Tax Severed Letter 2007-0237481R3 - Purchase of target and bump
(a) “ACB” has the meaning assigned to the expression “Adjusted Cost Base” in section 54 of the Act; (b) “Act” means the Income Tax Act, R.S.C. 1985 (5th Supp.) c. 1, as amended from time to time and consolidated to the date of this letter and, unless otherwise expressly stated, every reference herein to a part, section or subsection, paragraph or subparagraph and clause or subclause is a reference to the relevant provision of the Act; (c) “CBCA” means the Canada Business Corporations Act; (d) “CRA” means the Canada Revenue Agency; (e) “FMV” means fair market value; (f) “Initial Bid” means the initial unsolicited take-over bid announced on XXXXXXXXXX, by Xco, to acquire all of the shares of the capital stock of Parent, as described in Paragraph 27; (g) “Memorandum of Understanding” means the memorandum of understanding between Parent, Xco and other parties dated XXXXXXXXXX, as described in Paragraphs 28, 30 and 32; (h) “non-resident” has the meaning assigned by subsection 248(1); (i) “Offer” means the offer formally launched on XXXXXXXXXX, by Parent, through Bidco, to acquire all of the Target Shares, as amended on XXXXXXXXXX, as described in Paragraphs 12, 14, 16 and 17; (j) “paid-up capital” has the meaning assigned by subsection 89(1); (k) “Post-Take-over Merger” means the proposed merger of Xco with Parent, as described in Paragraph 30; (l) “private corporation” has the meaning assigned by subsection 89(1); (m) “public corporation” has the meaning assigned by subsection 89(1); (n) XXXXXXXXXX; (o) “Report” means the report filed on XXXXXXXXXX with Canadian securities commissions by the Investment Managers under XXXXXXXXXX; (p) “Revised Bid” means the amended bid made by Xco to acquire all of the shares of the capital stock of Parent, resulting from modifications made to the Initial Bid on XXXXXXXXXX, as described in Paragraph 28; (q) “Specified Shareholder” has the meaning assigned by subparagraph 88(1)(c.2)(iii) and subsection 248(1); (r) “subsidiary wholly-owned corporation” has the meaning assigned by subsection 248(1); (s) “Target Shares” means all of the issued and outstanding common shares of the capital stock of Target; (t) “taxable Canadian corporation” has the meaning assigned in subsection 89(1); (u) “Treaty” means the Convention Between The Government of Canada and XXXXXXXXXX; (v) XXXXXXXXXX. ...
Technical Interpretation - Internal
3 March 2023 Internal T.I. 2016-0662221I7 - Tax Sharing Payments made by LLCs
Income Tax Convention, and have an October 31 taxation year end. 18. The US Members of the US Consolidated Group elected to file an annual consolidated U.S. federal income tax return under section 1501 of the IRC. ...
Ruling
2020 Ruling 2019-0817051R3 - Reorganization
It is more efficient from a XXXXXXXXXX tax perspective for Foreign Parent to own the shares of the Forcos in a corporation that has access to the benefits of the tax convention between XXXXXXXXXX Certain other controlled foreign affiliates also ceased to be owned by a Canadian resident as a consequence of this transaction. ...
Ruling
2022 Ruling 2020-0859851R3 - Foreign accrual tax and underlying foreign tax
Internal Revenue Code of 1986, as amended to the date hereof; “CRA” means the Canada Revenue Agency; “equity percentage” has the meaning assigned by subsection 95(4); “excluded property” has the meaning assigned in subsection 95(1); “FA1” means XXXXXXXXXX, a corporation incorporated under the General Corporation Law XXXXXXXXXX; “FA2” means XXXXXXXXXX, a limited liability company formed under the laws XXXXXXXXXX; “FA2 common shares” means common shares in the capital stock of FA2; “FA2 preferred shares” means preferred shares in the capital stock of FA2 providing to the holder the right to vote, to have their shares redeemed at a fixed redemption amount of $XXXXXXXXXX per share and a fixed annual dividend entitlement of XXXXXXXXXX%; “fair market value” means the highest price available in an open and unrestricted market between informed and prudent parties dealing at arm’s length and under no compulsion to act, and contracting for a taxable purchase and sale, expressed in terms of money or money’s worth; “foreign accrual property income” has the meaning assigned in subsection 95(1); “foreign accrual tax” has the meaning assigned in subsection 95(1); “foreign affiliate” has the meaning assigned in subsection 95(1); “GPco” means XXXXXXXXXX, a limited liability company existing under the laws XXXXXXXXXX; “income from property” has the meaning assigned by subsection 95(1); “Intermediate LP” means a limited partnership formed or to be formed under the laws of a state of Country 1; “investment business” has the meaning assigned by subsection 95(1); XXXXXXXXXX; “Paragraph” refers to a numbered paragraph in this letter; “Parentco” means XXXXXXXXXX, a corporation existing under XXXXXXXXXX; “Property FA” means a limited liability company without share capital formed or to be formed under the laws of a state of Country 1; “Property LP” means a limited partnership formed or to be formed under the laws of a state of Country 1 (for greater certainty, a Property LP does not including an Intermediate LP); “Property Owner” refers to both the Property LPs and the Property FAs; “public corporation” has the meaning assigned by subsection 248(1); “REIT” means a “real estate investment trust” as defined in section 856(a) of the Country 1 Tax Law; “related person” has the meaning assigned by subsection 251(2); “share” has the meaning assigned by subsection 248(1) and includes all equity interests (within the meaning assigned by subsection 93.2(1)) in limited liability companies that are deemed to be shares under subsection 93.2(2); “Subparagraph” refers to a numbered subparagraph in this letter; “taxable Canadian corporation” has the meaning assigned by subsection 89(1); “taxable capital gain” has the meaning assigned by paragraph 38(a); “taxation year” has the meaning assigned in subsection 249(1); “Transactions” means the transactions described in the Transactions segment of this letter; “Treaty” means Canada-United States Income Tax Convention (1980), as amended; “underlying foreign tax” has the meaning assigned in subsection 5907(1) of the Regulations; “USLP1” means XXXXXXXXXX, a limited partnership existing under the laws XXXXXXXXXX; “USLP1 Limited Partner Unit” means a partnership interest of a limited partner in USLP1, representing a fractional part of the interests of all such partners in USLP1. ...
Old website (cra-arc.gc.ca)
Canada Revenue Agency Future Oriented Statement of Operations Agency Activities - Section III Supplementary Information-Financial Highlights
Section III Supplementary Information-Financial Highlights Previous page Next page Table 1: Agency Planned Spending and Full-Time Equivalents (thousands of dollars) Forecast Spending 2008-2009 Planned Spending 2009-2010 Planned Spending 2010-2011 Planned Spending 2011-2012 Program Activity Taxpayer and Business Assistance 380,755 732,108 301,977 299,849 Assessment of Returns and Payment Processing 884,676 615,892 610,178 610,471 Accounts Receivable and Returns Compliance 782,128 542,803 539,509 540,376 Reporting Compliance 1,392,634 922,168 919,006 915,080 Appeals 179,690 139,444 140,403 136,787 Benefit Programs 384,088 331,916 337,344 342,364 Internal Services – 1,377,922 1,373,801 1,370,068 Taxpayers’ Ombudsman – 3,328 3,330 3,330 Budgetary Main Estimates (gross) 4,003,971 4,665,580 4,225,548 4,218,325 Less: Revenues Credited to the Vote 1 266,610 277,606 282,766 285,732 Total Main Estimates 3,737,361 4,387,974 3,942,782 3,932,593 Adjustments Carry Forward from 2007-2008 134,871 – – – Supplementary Estimates Corporate Tax Administration for the Province of Ontario 64,969 – – – 2007 Economic Statement 17,880 – – – 2008 Federal Budget Initiatives (Part I) 7,797 – – – Foreign Convention and Tour Incentive Program 6,226 – – – Transfer from Public Works and Government Services Canada for Accommodation Services 22,021 – – – Office of Director of Public Prosecutions 1,109 – – – Advertising Campaign 6,000 – – – Wage Earner Protection Program 316 – – – Transfer from Public Health Agency for Advertising Campaign 1,225 – – – Transfer to Treasury Board Secretariat for Public Service Modernization Act (245) – – – Transfer to Canada Public Service Agency to support National Managers’ Community (200) – – – 2008 Federal Budget Initiatives (Part II) 22,685 – – – Statutory Payment – Softwood Lumber 419,000 – – – Statutory Payment – Energy Cost Assistance Measures 1,210 – – – Budget 2008 Strategic Review Reductions – Private Collection Agencies (6,000) – – – Transfer from Human Resources and Skills Development Canada for the Canada Disability Savings Program 201 – – – 564,194 – – – Technical Adjustments: Collective agreements/Contract awards 37,191 – – – Maternity and Severance Payments (to September 30, 2008) 36,112 – – – 2008-2009 Adjustment to Respendable Revenues 49,622 – – – Adjustment to Canada Pension Plan/Employment Insurance – Vote 1 (2,784) – – – 2008-2009 Adjustment to Revenues Credited to Vote 1 2,784 – – – Adjustment to Employee Benefit Plan 32,361 – – – Offshore Trusts Initiative (legislation pending) (24,343) – – – 130,943 – – – Total Adjustments 830,008 – – – Total Planned Spending 4,567,369 4,387,974 3,942,782 3,932,593 Less: Respendable Revenue pursuant to the Canada Revenue Agency Act 210,885 204,803 210,005 213,899 Non-Respendable Non-Tax Revenue (Agency Activities) 56,770 54,183 54,994 54,936 Plus: Cost of services received without charge 251,259 259,782 262,098 263,655 Total Agency Spending 4,550,973 4,388,770 3,939,881 3,927,413 Full-Time Equivalents (Planned) 39,795 39,481 39,325 39,286 Table 3: Services Received Without Charge [Footnote 1] (thousands of dollars) 2008-2009 2009-2010 2010-2011 2011-2012 Contributions covering employer’s share of employees’ insurance premiums and expenditures (excluding revolving funds) and employer’s contribution to employees’ insured benefits plans and expenditures, both paid by Treasury Board of Canada Secretariat (TBS) 194,426 206,711 207,234 206,916 Salary and associated expenditures of legal services provided by Justice Canada 50,761 47,202 49,090 51,054 Audit Services by the Office of the Auditor General 2,470 2,470 2,470 2,470 Workers’ Compensation coverage provided by Human Resources and Skills Development Canada (HRSDC) 2,090 1,887 1,792 1,703 Payroll Services provided by Public Works and Government Services Canada (PWGSC) 1,512 1,512 1,512 1,512 Total Services received without charge 251,259 259,782 262,098 263,655 [Footnote 1] Services received without charge are reported on a gross basis. ...
Old website (cra-arc.gc.ca)
Part XVIII Information Return – International Exchange of Information on Financial Accounts
Tax Convention Legislation (select "Part XVIII – Enhanced International Information Reporting") Registering for a GIIN Date modified: 2017-05-01 ...
Archived CRA website
ARCHIVED - 1995 General Income Tax Guide
Note Under proposed changes to the Canada-United States Tax Convention, starting in 1996, you will no longer be taxed in Canada on your U.S. social security benefits. ...
Old website (cra-arc.gc.ca)
Questions and answers about Line 115 - Pensions from a foreign country
There is a different reporting method for Italian pensions for 2011 and subsequent years based on the Canada-Italy Income Tax Convention signed on June 3, 2002 and which entered into force on November 25, 2011. ...