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فهرست مطالب :
Byrd & Chen’s Canadian Tax Principles 2020–2021 Edition, Volume I
Copyright
Contents
Preface
Acknowledgments
CHAPTER 1: Introduction To Federal Taxation In Canada
The Canadian Tax System
Alternative Tax Bases
Taxable Entities In Canada
Federal Taxation And The Provinces
Tax Policy Concepts
Taxation And Economic Policy
Taxation And Income Levels
Tax Incidence
Tax Expenditures
Qualitative Characteristics Of Tax Systems
Income Tax Reference Materials
Introduction
The Income Tax Act
Other Income Tax Legislation
Other Sources Of Income Tax Information
Liability For Part I Income Tax
Background
Charging Provision For Canadian Residents
Charging Provision For Non-Residents
Residence
Importance
Residence Of Individuals
Residence Of Corporations
Residence Of Trusts
Alternative Concepts Of Income
The Economist’s View
The Accountant’s View
The Income Tax Act View
Net Income For Tax Purposes
Structure
Components
Combining The Components - ITA Section 3
Loss Carry Overs
Net Income For Tax Purposes - Example
Net Income To Taxable Income
Principles Of Tax Planning
Introduction
Tax Avoidance Or Reduction
Tax Deferral
Income Splitting
Abbreviations To Be Used
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 2: Procedures And Administration
Introduction
Administration Of The Department
Returns And Payments - Individuals
Requirement To File - ITA 150
Due Date For Individual Returns
Withholdings For Income Tax - ITA 153
Instalment Payments For Individuals - ITA 156
Interest
Penalties
Due Date For Balance Owing - Living Individuals
Deceased Taxpayers - Balance Due Dates And Final Returns
Returns And Payments - Corporations
Due Date For Corporate Returns - ITA 150
Filing Alternatives For Corporations
Instalment Payments For Corporations
Due Date For Balance Owing - Corporations
Interest And Penalties For Corporations
Returns And Payments - Trusts
Types Of Trusts
Filing Requirements
Due Dates For Returns
Payment Of Taxes
Interest And Penalties
Income Tax Information Returns
Books And Records
Assessments And The CRA My Account Service
CRA Website - My Account Service
Notice Of Assessment
Notice Of Reassessment
Refunds
Adjustments To Income Tax Returns
Disputes And Appeals
Representation By Others
Informal Request For Adjustments
Notice Of Objection
Tax Court Of Canada
Federal Court And Supreme Court Of Canada
Tax Evasion, Avoidance, And Planning
Tax Evasion
Tax Avoidance And Tax Planning
General Anti-Avoidance Rule (GAAR)
Collection And Enforcement
Taxpayer Property
Collections
Other Penalties
Taxpayer Relief Provisions
Fairness Package
Voluntary Disclosure
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 3: Income Or Loss From An Office Or Employment
Employment Income Defined
General Rules
Cash Basis And The Use Of Bonus Arrangements
Net Concept
Employee Versus Self-Employed
Introduction
Employee Perspective
Employer Perspective
Making The Distinction
Inclusions - Employee Benefits
Basic Concepts
Inclusions - Salaries And Wages
Inclusions - Non-Salary Benefits
Introduction
Legislative Guidance
Non-Legislative Guidance
Tax Planning Considerations
Inclusions - GST/HST/PST On Taxable Benefits
Inclusions - Automobile Benefits
Employees And Automobiles
Taxable Benefits - Standby Charge
Operating Cost Benefit
Payments By Employee For Automobile Use
Summary Of Automobile Benefit Calculations
Example - Employer Owned Automobile
Example - Employer Leased Vehicle
Employer Provided Cars And Tax Planning
Inclusions - Allowances
Allowance Vs. Reimbursement
General Rules
Taxable Vs. Non-Taxable Allowances
Reasonable Allowances For Motor Vehicles
Employer’s Perspective Of Allowances
Employee’s Perspective Of Allowances
Inclusions - Employee Insurance Benefits
Life Insurance
Disability Insurance (a.k.a. Group Sickness Or Accident Insurance Plans)
Loans To Employees
General Rules
Tax Planning For Interest Free Loans
Inclusions - Stock Option Benefits
The Economics Of Stock Option Arrangements
Overview Of The Tax Rules
CCPCs Vs. Public Companies
Rules For Public Companies
Rules For Canadian Controlled Private Corporations (CCPCs)
Other Inclusions
Payments By Employer To Employee
Forgiveness Of Employee Loans
Housing Loss Reimbursement
Discounts On Employer’s Merchandise
Specific Deductions
Overview
Salesperson’s Expenses Under ITA 8(1)(f)
Travel Expenses And Motor Vehicle Costs Under ITA 8(1)(h) and 8(1)(h.1)
The Salesperson’s Dilemma
Other Expenses Of Performing Duties Under ITA 8(1)(i)
Automobile And Aircraft Expenses Under ITA 8(1)(j)
Work Space In The Home Costs For Employees
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 4: Taxable Income And Tax Payable For Individuals
Introduction
Taxable Income Of Individuals
Available Deductions
Ordering Of Deductions
Deductions For Payments - ITA 110(1)(f)
Northern Residents Deductions - ITA 110.7
Calculation Of Tax Payable
Federal Tax Payable Before Credits
Provincial Tax Payable Before Credits
Types Of Income
Taxes On Income Not Earned In A Province
Calculating Tax Credits
Federal Amounts
Provincial Amounts
Personal Tax Credits - ITA 118(1)
Basic Personal Amount (BPA) - ITA 118(1.1)
Individuals With A Spouse Or Common-Law Partner - ITA 118(1)(a)
Individuals Supporting A Dependent Person - ITA 118(1)(b)
Canada Caregiver Amount For Child - ITA 118(1)(b.1)
Single Persons (Basic Personal Tax Credit) - ITA 118(1)(c)
Canada Caregiver Tax Credit - ITA 118(1)(d)
Other Tax Credits For Individuals
Age Tax Credit - ITA 118(2)
Pension Income Tax Credit - ITA 118(3)
Canada Employment Tax Credit - ITA 118(10)
Adoption Expenses Tax Credit - ITA 118.01
Digital News Subscriptions Credit - ITA 118.02
Home Accessibility Tax Credit - ITA 118.041
First-Time Home Buyer’s Tax Credit - ITA 118.05
Volunteer Firefighters And Volunteer Search And Rescue Workers Tax Credits - ITA 118.06 And 118.07
Charitable Donations Tax Credit - ITA 118.1
Medical Expense Tax Credit - ITA 118.2
Disability Tax Credit - ITA 118.3
Education Related Tax Credits
Employment Insurance (EI) And Canada Pension Plan (CPP) Tax Credits - ITA 118.7
Overpayment Of EI Premiums And CPP Contributions
Transfers To A Spouse Or Common-Law Partner - ITA 118.8
Political Contributions Tax Credits - ITA 127(3)
Labour Sponsored Venture Capital Corporations Credit - ITA 127.4
Dividend Tax Credit
Foreign Tax Credits
Investment Tax Credits
Refundable Credits
Introduction
GST/HST Credit - ITA 122.5
Refundable Medical Expense Supplement - ITA 122.51
Canada Workers Benefit - ITA 122.7 (Formerly Working Income Tax Benefit)
Refundable Teacher And Early Childhood Educator School Supply Tax Credit - ITA 122.9
Climate Action Incentive Payments
Canada Training Credit - ITA 122.91
Social Benefits Repayment (OAS And EI)
Basic Concepts
Employment Insurance (EI) Benefits Clawback
Old Age Security (OAS) Benefits Clawback
Comprehensive Example
Key Terms Used In This Chapter
References
Sample Tax Return And Tax Software SS Problem
Problems For Self Study (Online)
Assignment Problems
Tax Software Assignment Problems
CHAPTER 5: Capital Cost Allowance
Note On Eligible Capital Expenditures
Capital Cost Allowance System
General Rules
Tax And Accounting Procedures Compared
Additions To Capital Cost
Determination Of Amounts
Available For Use Rules
Segregation Into Classes
Capital Cost Allowances
General Overview
Rates For Commonly Used CCA Classes
Half-Year Rules (a.k.a. First Year Rules)
Accelerated Investment Incentive (AccII)
Zero Emission Vehicles
Short Fiscal Periods
Class 14.1
Tax Planning Considerations For CCA
Dispositions Of Depreciable Assets
Overview Of Procedures
Capital Gains
Recapture Of Capital Cost Allowance
Terminal Losses
Dispositions Of Class 54 Assets (Zero Emission Vehicles)
Dispositions Of Class 14.1 – Differences From Other Classes
Summary Of Disposition Tax Consequences
CCA Schedule
CCA Determination - Special Situations
Separate Class Election
Change In Use For Automobiles
Other Special Situations
Key Terms Used In This Chapter
References
Appendix - CCA Rates For Selected Assets
Problems For Self Study (Online)
Assignment Problems
CHAPTER 6: Income Or Loss From A Business
Overview
Classification Of Income
Business Income Vs. Property Income
Tax Consequences Of Classification
Business Income Defined
Property Income Defined
Business Income Vs. Capital Gains
Tax Consequences Of Classification
Capital Gains Defined
Criteria For Identifying Capital Gains
Business Income And GAAP
Business Income - Inclusions (Revenues)
Inclusions In Business Income -Income Tax Act Provisions
Amounts Received And Receivable
Reserves
Other Inclusions
Limitations On Deductions From Business And Property Income
General Approach - Restrictions In ITA 18 Through ITA 19.1
Specific Limiting Items Under ITA 18
Foreign Media Advertising - ITA 19 And 19.1
Limitations On Deductions From Business, Property, And Employment Income
Introduction
Reasonableness
Meals And Entertainment
“Luxury” Automobile Costs
Automobiles Owned By The Taxpayer
Automobile Leasing Costs - ITA 67.3
Leasing Property
Illegal Payments, Fines And Penalties - ITA 67.5 And 67.6
Business Income - Specific Deductions
Inventory Valuation (Cost Of Sales)
Other Deductions
Reconciliation Schedule
Business Income - Example
Example Data
Example Analysis
Taxation Year
General Rules
Unincorporated Businesses - Non-Calendar Fiscal Year
Special Business Income Situations
Income For Farmers
Professional Income (Billed Basis Of Recognition)
Sale Of A Business
Scientific Research And Experimental Development
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 7: Income From Property
Introduction
Property Income: General Concept
Interest As A Deduction
The Problem
IT Folio S3-F6-C1 “Interest Deductibility”
What Is Interest?
Legislation
Borrowed To Produce Income
Direct Or Indirect Use
Discount And Premium On Long Term Issued Debt
Interest Income
General Provision
Corporations And Partnerships - Full Accrual Method
Individuals - Modified Accrual Method
Discount And Premium On Long Term Debt Holdings
Accrued Interest At Transfer
Payments Based On Production Or Use (Royalties)
Rental Income
General Rules
Capital Cost Allowances
Rental Income Example
Cash Dividends From Taxable Canadian Corporations
The Concept Of Integration
Implementing Integration
Gross Up And Tax Credit Procedures-Eligible Dividends
Gross Up And Tax Credit Procedures-Non-Eligible Dividends
Income Trusts
How Do Trusts Work?
Investments In Publicly Traded Trusts
Taxation Of Real Estate Investment Trusts (REITs)
Mutual Funds
Objective
Organization
Distributions
Adjusted Cost Base
Other Types Of Dividends
Capital Dividends
Stock Dividends
Foreign Source Income
General Rules
Foreign Non-Business (Property) Income
Foreign Business Income
Shareholder Benefits
Tax Credits Revisited
Dividend Tax Credits
Foreign Income Tax Credits
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 8: Capital Gains And Capital Losses
Economic Background
Capital Assets And Income Taxation Policy
Lifetime Capital Gains Deduction
Changes In The Inclusion Rate
General Rules
Capital Gains In The Income Tax Act
Capital Gains Defined
Dispositions
Proceeds Of Disposition
Adjusted Cost Base
Calculating The Capital Gain Or Loss
Detailed Application Of The Rules
Identical Properties
Partial Dispositions
Warranties On Capital Assets
Capital Gains Reserves
Bad Debts On Sales Of Capital Property
Special Rule For Sales Of Real Property
Provisions For Special Assets
Principal Residence
Personal Use Property
Listed Personal Property
Gains And Losses On Foreign Currency
Options - ITA 49
Deemed Dispositions - Change In Use
General Rules
Business To Personal Use
Personal To Business Use
Example - Change In Use
Special Rules For Principal Residences
Special Rules For Automobiles
Deemed Dispositions - Departures From Canada
Deferral Provisions On Small Business Investments
Basic Provision
Definitions
Example
Deferral Provisions On Replacement Property
The Problem
Voluntary And Involuntary Dispositions
Timing Considerations
Application Of ITA 44(1) To Capital Gains
Application Of ITA 13(4) To Recapture Of CCA
Combined Application Of ITA 13(4) And 44(1)
Capital Gains And Tax Planning
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 9: Other Income, Other Deductions, And Other Issues
Introduction
Coverage Of Chapter 9
Other Income - Subdivision d Inclusions
Pension Benefits - ITA 56(1)(a)(i)
Retiring Allowances - ITA 56(1)(a)(ii)
Death Benefits - ITA 56(1)(a)(iii)
Income Inclusions From Deferred Income Plans -ITA 56(1)(h), (h.1), (h.2), (i), and (t)
Scholarships And Prizes - ITA 56(1)(n)
Research Grants - ITA 56(1)(o)
Social Assistance And Workers’ Compensation Payments - ITA 56(1)(u) And (v)
Other Deductions - Subdivision e Deductions
CPP Contributions On Self-Employed Earnings - ITA 60(e) and ITA 60(e.1)
Moving Expenses - ITA 62
Child Care Expenses - ITA 63
Disability Supports Deduction - ITA 64
Related Inclusions And Deductions
Introduction
Employment Insurance Benefits - ITA 56(1)(a)(iv) And 60(n)
Pension Income Splitting - ITA 56(1)(a.2) And 60(c)
Spousal And Child Support - ITA 56(1)(b) And 60(b)
Annuity Payments Received - ITA 56(1)(d) And 60(a)
Registered Savings Plans
Introduction
Tax Free Savings Accounts (TFSAs)
Registered Education Savings Plans (RESPs)
Registered Disability Savings Plans (RDSPs)
Non-Arm’s Length Transfers Of Property
Introduction
Inadequate Considerations - ITA 69
Inter Vivos Transfers To A Spouse - ITA 73(1) And 73(1.01)
Non-Arm’s Length Transfers Of Depreciable Assets - ITA 13(7)(e)
Inter Vivos Transfer Of Farm Or Fishing Property To A Child
Death Of A Taxpayer
Income Attribution
The Problem
Basic Rules - ITA 74.1(1) And (2)
Avoiding Income Attribution
Income Attribution - Other Related Parties
Anti-Avoidance Provisions
Tax Planning And Income Attribution
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 10: Retirement Savings And Other Special Income Arrangements
Planning For Retirement
Introduction
Providing Consistency
Tax Deferred Savings
Defined Benefit Vs. Money Purchase Plans
Registered Retirement Savings Plans (RRSPs)
Basic Operations
RRSP Deduction Limit
Examples Of RRSP Deduction Calculations
Undeducted RRSP Contributions
RRSP And RRIF Administration Fees
RRSP Withdrawals And Voluntary Conversions
Involuntary Termination Due To Age Limitation
Spousal RRSP
Home Buyers’ Plan (HBP)
Lifelong Learning Plan (LLP)
Departure From Canada
Death Of The RRSP Registrant
Registered Pension Plans (RPPs)
Establishing An RPP
Employer Contributions To The RPP
Employee Contributions To The RPP
Options At Retirement
Phased Retirement
Inadequate Retirement Savings
Registered Retirement Income Funds (RRIFs)
Establishment
RRIF Withdrawals
Death Of The RRIF Registrant
Evaluation Of RRIFs
Deferred Profit Sharing Plans
General Rules
Tax Planning
Profit Sharing Plans
General Rules
Part XI.4 Tax On Excess PSP Contributions
Transfers Between Plans
Accumulated Benefits
Retiring Allowances
Retirement Compensation Arrangements
The Problem
Arrangements Defined
Part XI.3 Refundable Tax
Salary Deferral Arrangements
The Problem
The Solution
Individual Pension Plans (IPPs)
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
Index
Byrd & Chen’s Canadian Tax Principles 2020–2021 Edition, Volume II
Copyright
Contents
Preface
CHAPTER 11 : Taxable Income And Tax Payable For Individuals Revisited
Introduction
The Problem
Our Solution
Taxable Income Overview
Lump Sum Payments
The Problem
Treatment Of Losses
Carry Over Provisions
Personal Use Property Losses
Listed Personal Property Losses
Non-Capital Losses
Net Capital Losses
Net Capital Losses At Death
Allowable Business Investment Losses
Farm Losses
Lifetime Capital Gains Deduction
Background
Current And Future Limits
Qualified Property
Determining The Deductible Amount
Comprehensive Example
Ordering Of Deductions And Losses
Significance Of Ordering
Ordering In Computing Net Income For Tax Purposes
Ordering In Computing Taxable Income
Example
Tax Payable Overview
General
Basic Federal Tax Payable
Tax On Split Income (TOSI)
A Note Of Caution
Background
Determining Applicability
Excluded Amounts
Calculation Of The Tax
Tax Credits Revisited
Transfer Of Dividends To A Spouse Or Common-Law Partner
Charitable Donations Credit Revisited – Introduction
Foreign Tax Credits Revisited
Alternative Minimum Tax
General Concept
Minimum Tax Calculation
Tax Credits For AMT
AMT Carry Forward - ITA 120.2
Sample Comprehensive Personal Tax Return
Key Terms Used In This Chapter
References
Appendix - Returns For Deceased Taxpayers
Special Rules At Death
Representation
Procedures For Specific Returns
Filing Requirements
Use Of Deductions And Credits
Payment Of Taxes
Sample Tax Return and Tax Software SS Problem
Problems For Self Study (Online)
Assignment Problems
Tax Software Assignment Problems
CHAPTER 12: Taxable Income And Tax Payable For Corporations
Recent Developments In Corporate Taxation
Small Business Deduction Rate
Tax Planning By Private Corporations
Computation Of Net Income
Computation Of Taxable Income
Deductions Available To Corporations
Dividends From Other Corporations
Non-Capital Loss Carry Over For A Corporation
Ordering Of Taxable Income Deductions
Geographical Allocation Of Income
Permanent Establishments
Activity At Permanent Establishments
Example - Permanent Establishments
Federal Tax Payable
Basic Rate
Federal Tax Abatement
General Rate Reduction
Provincial Tax Payable
General Rules
General Rate
Manufacturing And Processing Rate
Small Business Rate
Investment Income Rates
Other Provincial Taxes
Other Goals Of The Corporate Tax System
Small Business Deduction
Introduction
Canadian Controlled Private Corporation (CCPC)
Active Business Income
Annual Business Limit
Allocation Among Associated Companies
Calculating The Small Business Deduction
Annual Business Limit Reduction
Personal Services Corporations
Professional Corporations And Management Companies
Manufacturing And Processing Profits Deduction
Introduction
Calculating The Deduction
Eligibility
M&P Profits Defined
General Rate Reduction - ITA 123.4(2)
Approach To Rate Reductions
Full Rate Taxable Income
Application To Companies Other Than CCPCs
Application To CCPCs
Foreign Tax Credits For Corporations
Introduction
Calculation Of Foreign Tax Credits
Refundable Journalism Labour Tax Credit
Described
Definitions - ITA 125.6
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 13: Taxation Of Corporate Investment Income
Note On Current Developments
Integration
The Basic Concept
Eligible Vs. Non-Eligible Dividends
Rates Required For Integration
Refundable Taxes On Investment Income
Meaning Of Aggregate Investment Income
Basic Concepts
Refundable Part I Tax On Investment Income
Additional Refundable Tax On Investment Income (ART)
Problem One: Excessive Tax Rates On The Flow Through Of A CCPC’s Investment Income
Solution To Problem One: Refundable Portion Of Part I Tax
Refundable Part IV Tax On Dividends Received
Problem Two: Use Of Multi-Level Affiliations To Defer Taxes On Investment Income
Solution To Problem Two: Refundable Part IV Tax
Part IV Tax On Portfolio Dividends Received
Dividends From A Connected Corporation
Dividends Paid Out Of Mixed Income Of A Connected Corporation
Other Part IV Tax Considerations
Designation Of Eligible Dividends
Basic Concepts
CCPCs And Their GRIP
Non-CCPCs And Their LRIP
Part III.1 Tax On Excessive Eligible Dividend Designations
A Final Word On Eligible Dividends
Refundable Dividend Tax On Hand (RDTOH)
Background
Transitional Provision
Part IV Tax Payable
Refundable Part I Tax Payable
RDTOH Balances Defined
The Dividend Refund
Economic Impact Of Changes
Example Of RDTOH Calculations
Working Through Large Corporate Tax Problems
Key Terms Used In This Chapter
References
Sample Corporate Tax Return For Chapter 13
Problems For Self Study (Online)
Assignment Problems
CHAPTER 14: Other Issues In Corporate Taxation
Introduction
Acquisition Of Control Rules
Economic Background
Acquisition Of Control Legislation
Deemed Year End
Restrictions On The Use Of Losses
Unrecognized Losses At Deemed Year End
Deemed Disposition Election
Associated Companies
The Problem
Definitions
Examples - Associated Corporation Rules
Investment Tax Credits
Background
Procedures
Eligible Expenditures
Rates
Refundable Investment Tax Credits
Carry Overs Of Investment Tax Credits
Effect Of Acquisition Of Control On Investment Tax Credits
Tax Basis Shareholders’ Equity
Shareholders’ Equity Under GAAP
Paid Up Capital (Tax Basis Contributed Capital)
Tax Basis Retained Earnings
Capital Dividend Account (CDA)
Distributions Of Corporate Surplus
Introduction
Regular Cash Dividends
Stock Dividends
Dividends In Kind
Capital Dividends Under ITA 83(2)
Deemed Dividends Under ITA 84(1) -Increase In PUC
Deemed Dividends Under ITA 84(2) -On Winding-Up
Deemed Dividends Under ITA 84(3) -On Redemption, Acquisition, Or Cancellation Of Shares
Deemed Dividends Under ITA 84(4) And ITA 84(4.1)
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
Tax Software Assignment Problem
CHAPTER 15: Corporate Taxation And Management Decisions
The Decision To Incorporate
Basic Tax Considerations
Other Advantages And Disadvantages
Tax Reduction And Deferral
Approach
Basic Example
Public Corporation
CCPC - Active Business Income
CCPC - Investment Income Other Than Dividends
CCPC - Dividend Income
Conclusions On Tax Reductions And Deferrals
Provincial Taxes And Integration
Introduction
Tax Deferral
Tax Reduction
Examples - Effects Of Provincial Rates On Integration
Summary: Tax Deferral And Tax Reduction
Tax Free Dividends
Tax Rates On Dividends
Use Of Tax Credits
Tax Free Amounts For 2020
Income Splitting
Basic Concept
Shareholder Benefits Including Loans
The Owner-Manager Environment
Shareholder Benefits Other Than Loans
Shareholder Loans
Management Compensation
General Principles
Salary Vs. Dividends
Salary Vs. Dividends For The Owner-Manager
The Basic Trade-Off
Other Considerations
Conclusion
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 16: Rollovers Under Section 85
Rollovers Under Section 85
Introduction
General Rules For The Transfer
Transferor And Transferee
Eligible Property
Consideration To Transferor
Making The Election
Selecting The Transfer Price
Transfer Prices - Detailed Rules
Rules Applicable To All Assets
Accounts Receivable
Inventories And Non-Depreciable Capital Property
Non-Depreciable Capital Property -Disallowed Capital Losses
Depreciable Property
Depreciable Property – Disallowed Terminal Losses
Summary Of Transfer Price Rules
Allocation Of The Elected Value
Consideration Received By The Transferor (Shareholder)
Assets Acquired By The Corporation
Paid Up Capital (PUC) Of Shares Issued
General Rules
Paid Up Capital Reduction
More Than One Class Of Shares
Comprehensive Example - Section 85 Rollovers
Basic Information
Excluded Assets
Implementing The Election
Gift To Related Party - Section 85
General Rules
Example
Excess Consideration - Section 85
Introduction
Shareholder Benefit - ITA 15(1)
Dividend Stripping — ITA 84.1
Background
Applicability Of ITA 84.1
Dividend Stripping Example
Capital Gains Stripping — ITA 55(2)
The Problem
Application Of ITA 55(2)
Capital Gains Stripping - Example One
Capital Gains Stripping - Example Two
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 17: Other Rollovers And Sale Of An Incorporated Business
Introduction
Share For Share Exchanges - ITA 85.1
Background
General Rules
Conditions For The Application Of ITA 85.1
Example
Exchange Of Shares In A Reorganization - ITA 86
Application Of ITA 86(1)
Conditions For The Reorganization
Procedures
Example Using ITA 86(1) In An Estate Freeze
Gift To Related Person - ITA 86(2)
Using ITA 86(1) - Tax Planning Considerations
Amalgamations - ITA 87
The Nature Of An Amalgamation
Position Of The Amalgamated Company
Position Of The Shareholders
Vertical Amalgamations
Asset Bump-Ups
Non-Tax Considerations
Amalgamations - Tax Planning Considerations
Winding-Up Of A 90 Percent Owned Subsidiary
The Nature Of A Winding-Up
Acquisition Of Assets
Disposition Of Shares
Tax Planning Considerations - Amalgamation Vs. Winding-Up
Winding-Up Of A Canadian Corporation
The Nature Of The Transaction
Example
Convertible Properties
Application
Other Considerations
Sale Of An Incorporated Business
Alternatives
Restrictive Covenants (a.k.a. Non-Competition Agreements)
Sale Of Individual Assets
Sale Of Assets As A Going Concern
Sale Of Shares
Evaluation Of Alternatives
Example
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 18: Partnerships
Introduction
Taxable Entities In Canada
Chapter Coverage
Partnerships Defined
The Importance Of Defining A Partnership
Basic Partnership Elements
Types Of Partnerships
Co-Ownership, Joint Ventures, And Syndicates
Introduction
Co-Ownership
Joint Ventures
Syndicates
Partnership Income, Losses, And Tax Credits
Introduction
Applicable Concepts
Calculating The Amounts To Be Allocated
Methods Of Allocation
The Partnership Interest
The Concept
Acquiring A Partnership Interest
Adjusted Cost Base Of The Partnership Interest
Disposition Of A Partnership Interest
Limited Partnerships And Limited Partners
Definitions
At-Risk Rules
Transfer Of Property To And From A Partnership
Definition Of Canadian Partnership
Transfers With No Rollover Provision
Common Partnership Rollovers
Specified Investment Flow Through Partnerships
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 19: Trusts And Estate Planning
Introduction
Basic Concepts
What Is A Trust?
Establishing A Trust
Returns And Payments - Trusts
Non-Tax Reasons For Using Trusts
Classification Of Trusts
Introduction
Personal Trusts
Testamentary Trusts
Inter Vivos Trusts
Taxation Of Trusts
Taxation Year
The Basic Taxation Model
Rollovers To A Trust
Rollovers To Capital Beneficiaries
21 Year Deemed Disposition Rule
Other Deemed Dispositions
Net Income For Tax Purposes Of A Trust
Basic Rules
Preferred Beneficiary Election
Amounts Deemed Not Paid
Amounts Retained For A Beneficiary Under 21 Years Of Age
Taxable Income Of A Trust
Income Allocations To Beneficiaries
General Rules
Discretionary And Non-Discretionary Distributions
Flow Through Provisions
Principal Residence Exemption
Tax Payable Of Personal Trusts
Calculation Of Basic Amount
Other Tax Payable Considerations
Income Attribution - Trusts
General Rules
Attribution To Settlor (Reversionary Trust)
Purchase Or Sale Of An Interest In A Trust
Income Interest
Capital Interest
Tax Planning
Family Trusts
Qualifying Spousal Or Common-Law Partner Trusts
Alter Ego Trusts
Joint Spousal Or Joint Common-Law Partner Trusts
Estate Planning
Non-Tax Considerations
Tax Considerations
Estate Freeze
Objectives Of An Estate Freeze
Techniques Not Involving Rollovers
Section 86 Share Exchange
Rollover Provisions - Section 85 vs. Section 86
SIFT Partnerships And Trusts
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 20: International Issues In Taxation
Introduction
Subjects Covered
The Role of International Tax Treaties
Part I Tax On Non-Residents
Introduction
Carrying on Business in Canada
Canadian Source Employment Income
Dispositions of Taxable Canadian Property
Part XIII Tax On Non-Residents
Introduction
Interest Payments
Dividend Payments
Royalty Payments
Rental Income
Pension Payments And Other Retirement Related Benefits
Shareholder Loans To Non-Residents
Immigration And Emigration
Entering Canada - Immigration
Departures From Canada - Emigration
Unwinding A Deemed Disposition
Short-Term Residents
Foreign Source Income Of Canadian Residents
Introduction
Foreign Investment Reporting Requirements
Foreign Source Employment Income
Foreign Source Business Income (Unincorporated Sources)
Foreign Source Interest Income
Foreign Source Capital Gains
Foreign Source Dividend Income - Problems
Foreign Source Dividends Received By Individuals
Foreign Dividends Received From Non-Affiliated Corporations
Dividends Received From Non-Controlled Foreign Affiliates
Dividends Received From Controlled Foreign Affiliates
Foreign Accrual Property Income (FAPI)
Key Terms Used In This Chapter
References
Problems For Self Study (Online)
Assignment Problems
CHAPTER 21: GST/HST
Introduction
Background
The Current Situation
How This Text Deals With This Complexity
Transaction Tax Concepts
General Description
Types Of Transaction Taxes
Liability For GST/HST
Basic Charging Provision
The Concept Of Supply
Supply Categories
Taxable Supplies
Exempt Supplies
Applying The GST/HST Rate
Place Of Supply
Applying The Rate
Collection And Remittance Of GST/HST
Registration
Meaning Of Person For GST/HST
Who Must Register
Exemption For Non-Residents
Exemption For Small Suppliers
Input Tax Credits
Vendors Of Fully Taxable And Zero-Rated Supplies
Vendors Of Exempt Supplies
Accounting vsIncome Tax vs. GST/HST
Example One - Fully Taxable And Zero-Rated Supplies
Example Two - Fully Taxable And GST Exempt Supplies
Relief For Small Businesses
Quick Method Of Accounting
Small Suppliers Exemption
Simplified Input Tax Credit Method
GST/HST Procedures And Administration
GST/HST Returns And Payments
Associated Persons
Refunds And Rebates
Books And Records
Appeals
General Anti-Avoidance Rule
Employee And Partner GST/HST Rebate
General Concept
Calculating The GST/HST Rebate Amount
Example
Residential Property And New Housing Rebate
General Rules For Residential Property
New Housing Rebate
Sale Of A Business
Sale Of Assets
Sale Of Shares
Other Situations
Specific Applications
Partnerships And GST/HST
General Rules
Partner Expenses
Disposition Of A Partnership Interest
Transfers Between Partners And Partnerships
Reorganization Of The Partnership
Trusts And GST/HST
Key Terms Used In This Chapter
Problems For Self Study (Online)
Assignment Problems
Index
Byrd & Chen’s Canadian Tax Principles 2020–2021 Edition (Study Guide)
Copyright
Contents
Preface
CHAPTER 1
Chapter 1 Learning Objectives
How to Work Through Chapter 1
Solutions to Chapter 1 Exercises
CHAPTER 2
Chapter 2 Learning Objectives
How to Work Through Chapter 2
Solutions to Chapter 2 Exercises
CHAPTER 3
Chapter 3 Learning Objectives
How to Work Through Chapter 3
Solutions to Chapter 3 Exercises
CHAPTER 4
Chapter 4 Learning Objectives
How to Work Through Chapter 4
Sample Personal Tax Return For Chapter 4
Suggestions For Working With ProFile Software
Tax Software Self Study Problem - Chapter 4
Solutions to Chapter 4 Exercises
Solution to Tax Software Self Study Problem - Chapter 4
CHAPTER 5
Chapter 5 Learning Objectives
How to Work Through Chapter 5
Solutions to Chapter 5 Exercises
CHAPTER 6
Chapter 6 Learning Objectives
How to Work Through Chapter 6
Solutions to Chapter 6 Exercises
CHAPTER 7
Chapter 7 Learning Objectives
How to Work Through Chapter 7
Solutions to Chapter 7 Exercises
CHAPTER 8
Chapter 8 Learning Objectives
How to Work Through Chapter 8
Solutions to Chapter 8 Exercises
CHAPTER 9
Chapter 9 Learning Objectives
How to Work Through Chapter 9
Solutions to Chapter 9 Exercises
CHAPTER 10
Chapter 10 Learning Objectives
How to Work Through Chapter 10
Solutions to Chapter 10 Exercises
CHAPTER 11
Chapter 11 Learning Objectives
How to Work Through Chapter 11
Sample Personal Tax Return For Chapter 11
Tax Software Self Study Problem - Chapter 11
Solutions to Chapter 11 Exercises
Solution to Tax Software Self Study Problem - Chapter 11
CHAPTER 12
Chapter 12 Learning Objectives
How to Work Through Chapter 12
Solutions to Chapter 12 Exercises
CHAPTER 13
Chapter 13 Learning Objectives
How to Work Through Chapter 13
Sample Corporate Tax Return
Solutions to Chapter 13 Exercises
CHAPTER 14
Chapter 14 Learning Objectives
How to Work Through Chapter 14
Solutions to Chapter 14 Exercises
CHAPTER 15
Chapter 15 Learning Objectives
How to Work Through Chapter 15
Solutions to Chapter Fifteen Exercises
CHAPTER 16
Chapter 16 Learning Objectives
How to Work Through Chapter 16
Solutions to Chapter 16 Exercises
CHAPTER 17
Chapter 17 Learning Objectives
How to Work Through Chapter 17
Solutions to Chapter 17 Exercises
CHAPTER 18
Chapter 18 Learning Objectives
How to Work Through Chapter 18
Solutions to Chapter 18 Exercises
CHAPTER 19
Chapter 19 Learning Objectives
How to Work Through Chapter 19
Solutions to Chapter Nineteen Exercises
CHAPTER 20
Chapter 20 Learning Objectives
How to Work Through Chapter 20
Solutions to Chapter 20 Exercises
CHAPTER 21
Chapter 21 Learning Objectives
How to Work Through Chapter 21
Solutions to Chapter 21 Exercises
Glossary
توضیحاتی در مورد کتاب به زبان اصلی :
Byrd & Chen’s Canadian Tax Principles provides straightforward answers to personal and corporate tax questions. With over 700 pages of reliable information, it will help you resolve tax issues in your general practice.
Turn to this easy-to-understand guide when you need straightforward answers to common personal, corporate or GST/HST tax questions. Written for professionals who include tax work in their general practice, Canadian Tax Principles will help to shine a light on the key issues in tax problems and provide you with the answers you need to solve them.