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Technical Interpretation - Internal summary

24 October 2006 Internal T.I. 2006-0203901I7 F - Avantage automobile -- summary under Paragraph 6(1)(a)

. In finding that this exception to a taxable benefit was inapplicable, CRA stated: According to the CRA, a pick-up point is a common place specifically designated by the employer for that purpose to which all employees must go. ...
Technical Interpretation - External summary

12 February 2007 External T.I. 2006-0214141E5 F - Régime d'assurance salaire -- summary under Subparagraph 6(1)(a)(i)

. Rather, the plan is the agreement between the employer and its employees or a group or association of employees that provides compensation to an employee for loss of employment due to illness or accident. ...
Technical Interpretation - External summary

16 November 2006 External T.I. 2006-0203131E5 F - Régime à traitement différé -- summary under Subsection 5(1)

However, in the year of resignation, i.e. 2006, since the salary for the last two pay periods was withheld to recover part of the prepaid salary, the amount of salary received by the employee- net of the deductions made by the employer was to be included in the employee's income for 2006 In addition, any cheques written by the employee in 2006 for prepaid salary reimbursements would reduce his employment income for 2006 and, if repaid in 2007, would reduce the employee's 2006 employment income, so that the employer would be required to file an amended T4 slip for that taxation year. ...
Technical Interpretation - External summary

18 April 2005 External T.I. 2004-0093821E5 F - Fiducie créée par testament -- summary under Subparagraph (c)(i)

Thus, in such a situation, the trust would no longer be a "testamentary trust" …. ...
Technical Interpretation - Internal summary

16 May 2005 Internal T.I. 2005-0119061I7 F - Montant d'aide-actions -- summary under Paragraph (a)

Since the loan from M Co is assistance that is required to be included in Prod Co's income under paragraph 12(1)(x), the conversion of the loan by M Co into shares of Prod Co at the end of the production would not engage the application of subsection 80(2). ...
Conference summary

7 October 2005 Roundtable, 2005-0138111C6 F - Actions donnant droit au produit d'assurance-vie -- summary under Subsection 70(5)

CRA confirmed that, regarding the narrow issue of the FMV of the common shares immediately before the death of the taxpayer, given that the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares so that the value of the common shares would not take the policy CSV into account. ...
Technical Interpretation - External summary

8 November 2005 External T.I. 2005-0148091E5 F - Résidence principale-deux unités de condominium -- summary under Principal Residence

On the other hand, if one unit has all the bedrooms and the other unit consists primarily of the kitchen and bathrooms and they are truly used as one unit, the CRA may be more likely to conclude that there is a single unit for purposes of the definition of "principal residence" …. ...
Technical Interpretation - External summary

22 December 2005 External T.I. 2005-0151091E5 F - Allocation de retraite - retenue à la source -- summary under Paragraph 100(3)(c)

22 December 2005 External T.I. 2005-0151091E5 F- Allocation de retraite- retenue à la source-- summary under Paragraph 100(3)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) confirmation of RRSP deduction limit is not required from the employee for the portion of the retiring allowance that is eligible for deduction under paragraph 60(j.1) In response to a query as to whether the correspondent’s notice of assessment must be provided to the employer so that it can pay the retiring allowance amount into the individual’s RRSP without deductions at source and whether that amount can be paid into a spousal RRSP or as a repayment of the individual’s home buyers' plan ("HBP"), CRA stated: [T]he employer is not required to withhold tax on the amount of the retiring allowance that it pays directly to an RRSP if the employer has reasonable grounds to believe that the premium is deductible under paragraph 60(j.1) or subsection 146(5) or (5.1) in computing the employee's income for the taxation year in which the retiring allowance is paid. ...
Technical Interpretation - External summary

9 November 2017 External T.I. 2017-0704221E5 - Capital Dividend Account -- summary under Subsection 83(2.1)

Consequently, subsection 83(2.1) would not apply to deem a capital dividend received by Ms Y to be a taxable dividend. ...
Technical Interpretation - Internal summary

16 August 2017 Internal T.I. 2015-0622751I7 - Part XIII Tax on Benefit to Non-resident -- summary under Subsection 160(1)

Did the interest-free loan generate Part XIII tax and, if so, who had the obligation to collect and remit the tax and how could it be collected? ...

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