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Notice of Ways and Means Motion October 2018: Part IV Tax – Allocation of Losses

Part IV Tax – Allocation of Losses   ITA 129 New subsections 129(4.1) and (4.2) of the Act are introduced consequential to the introduction of the eligible refundable dividend tax on hand (ERDTOH) and non-eligible refundable dividend tax on hand (NERDTOH) accounts. These new subsections provide an allocation rule for situations in which losses are […]

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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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IT269R4- Part IV Tax on Taxable Dividends Received by a Private Corporation or a Subject Corporation

NO: IT-269R4 DATE: April 24, 2006 SUBJECT: INCOME TAX ACT Part IV Tax on Taxable Dividends Received by a Private Corporation or a Subject Corporation REFERENCE: Sections 186, 186.1 and 186.2 (also sections 112, 113 and 149, subsections 129(3), 187(1), 227(14) and 227(16) of the Income Tax Act (the “Act”) and Part LXVII of the Income Tax Regulations (the “Regulations))

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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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IT432R2- Benefits Conferred on Shareholders

NO.: IT-432R2 DATE: February 10, 1995 SUBJECT: INCOME TAX ACT Benefits Conferred on Shareholders REFERENCE: Subsection 15(1) (also sections 84 and 246; subsections 15(1.1) to 15(1.4), 15(7), 52(1), 52(1.1), 56(2) and 248(1) definitions of “property”, “corporation”, “shareholder” and “specified shareholder”; paragraphs 6(1)(a), 69(1)(b), 82(1)(a) and 214(3)(a); and subparagraph 129(1)(a)(i) of the Income Tax Act; and

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