125(7)

Notice of Ways and Means Motion April 2018: Passive Income, RDTOH, and Small Business Deduction Grind

Passive Investment Income   Budget 2018 Active business income earned by private corporations is taxed at corporate income tax rates that are generally lower than personal income tax rates, giving these corporations more money to invest in order to grow their business. In addition, a small Canadian-controlled private corporation (CCPC) can benefit from a corporate […]

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Income Tax Folio S4-F8-C1, Business Investment Losses

Series 4: Businesses Folio 8: Losses Chapter 1: Business Investment Losses Summary A taxpayer’s business investment loss is basically a capital loss from a disposition of shares in, or a debt owing to the taxpayer by, a small business corporation (SBC) where the disposition is: to an arm’s-length person; or one to which subsection 50(1) applies. One-half of this loss

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Income Tax Folio S3-F2-C1, Capital Dividends

Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the

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The “More Than Five Full-Time Employees” Test

The “More Than Five Full-Time Employees” Test In 489599 B.C. Ltd. v. The Queen, 7 a CCPC had five full‑time employees and two part‑time employees. The issue was whether the CCPC employed “more than five full‑time employees” for the purposes of the definition of “personal services business” set forth in subsection 125(7). The Tax Court of Canada concluded

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IT168R3- Athletes and players employed by football, hockey and similar clubs

NO: IT-168R3 DATE: May 13, 1991 SUBJECT: INCOME TAX ACT Athletes and Players Employed by Football, Hockey and Similar Clubs REFERENCE: Section 6 (subsection 2(3), sections 8, 115 and 212 and paragraphs 18(1)(p) and 125(7)(d) and the definitions of “retirement compensation arrangement” and “salary deferral arrangement” in subsection 248(1)) Application This bulletin cancels and replaces Interpretation

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IT113R4- Benefits to Employees – Stock Options

NO: IT-113R4 DATE: August 7, 1996 SUBJECT: INCOME TAX ACT Benefits to Employees – Stock Options REFERENCE: Section 7 (also subsections 2(3), 5(1), 8(12), 110(1.5), 115(1) and the definition of “Canadian-controlled private corporation” in subsection 125(7), paragraphs 6(1)(a), 53(1)(j) and 110(1)(d) and (d.1), and subparagraph 128.1(4)(b)(vi) of the Income Tax Act; and section 6204 of the

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IT243R4- Dividend Refund to Private Corporations

NO: IT-243R4 DATE: February 12, 1996 SUBJECT: INCOME TAX ACT Dividend Refund to Private Corporations REFERENCE: Section 129 (also sections 51, 84, 85.1, 86, 87, 88, 105, 123.2, 125, 150, and 157; subsections 12(10.2), 15(3), 85(1), 104(13) and (14), 126(1) and (2), 161(2), 186(2), 256(2), and 260(7); the definitions of “designated property” and “private corporation” in

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