Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查
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Administrative Policy summary
14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress -- summary under Article 19
14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 majority of arbitration Articles provide for baseball-style arbitration Approximately 20 of Canada’s treaties will be updated to include arbitration. ...
Administrative Policy summary
14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress -- summary under Article 4
14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 4 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 4 post MLI, most of Canada’s treaties will have a residence tie-breaker rule When the Notice of Ways and Means motion for the implementation of MLI was tabled, Canada indicated that it would adopt additional provisions of the MLI including the tie-breaker rule for dual-resident entities. ...
Administrative Policy summary
15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations” -- summary under Subsection 95(8)
15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations”-- summary under Subsection 95(8) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(8) Finance has issued a comfort letter respecting umbrella corporation interests where there is no tax avoidance purpose It is not clear to Finance that the compliance burden on a Canadian investor under the tracking interest rules is unusually onerous compared with other compliance obligations under this part of the Act. ...
Administrative Policy summary
Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)". -- summary under Subsection 127(11.4)
Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)".-- summary under Subsection 127(11.4) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(11.4) ...
Conference summary
25 November 2012 Roundtable, 2013-0479401C6 F - Employés et Achat Ltée commentaires panel ARC -- summary under Paragraph 251(1)(c)
25 November 2012 Roundtable, 2013-0479401C6 F- Employés et Achat Ltée commentaires panel ARC-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Buyco that is formed by employer to purchases departing employees’ shares is NAL In order to facilitate the disposition of shares of departing employees who had purchased their shares under an employee share ownership plan (ESOP), Opco forms and injects funds into a new company (Buyco), which uses those funds to purchase the employee’s Opco shares. ... This … is consistent with … 2007-0243171C6, 2002-0166655 and 2004-0103061E5 … Petro-Canada and … RMM …. ...
TCC (summary)
Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- summary under Payment & Receipt
The King, 2024 TCC 1 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt salary paid into her husband’s bank account was constructively received by the employee The appellant, a real estate brokerage firm, determined (based on agreement between its two employees) that the remuneration paid to them would be allocated as to $165,000 and $192,000 to Mrs. and Mr. ... Moreover, an amount of money is deemed received by an employee when it is available to the employee. … … [C]onstructive receipt applies with respect to Mrs. ...
Administrative Policy summary
14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT -- summary under Article 7(1)
14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) PPT applied 1st like any other Treaty benefit limitation rule, any remaining benefit subject to GAAR scrutiny Question: How to the GAAR and PPT interact? ... S. 4.1 of the ITCIA provides that “notwithstanding the provisions of a Convention … the GAAR, applies to any benefit provided under the Convention.” ...
Administrative Policy summary
3 November 1995 Interpretation 950229 – Sale of Rebuilt Cottage – ITCs on Costs Incurred for Rebuilding the Cottage -- summary under Section 192
3 November 1995 Interpretation 950229 – Sale of Rebuilt Cottage – ITCs on Costs Incurred for Rebuilding the Cottage-- summary under Section 192 Summary Under Tax Topics- Excise Tax Act- Section 192 rebuilding of fire-damaged cottage The subject cottage, that was rented out as a principal place of residence (ie., a residential complex) was subject to a fire in early 1995 that almost destroyed it. ...
Administrative Policy summary
IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993 -- summary under Subsection 147(10.1)
IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993-- summary under Subsection 147(10.1) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(10.1) 14. ...
Decision summary
Agence du revenu du Québec v. Structures GB Ltée, 2025 QCCA 134 -- summary under Rectification & Rescission
Structures GB Ltée, 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporate reorganization documents could not be rectified to correct for an unforeseen Pt. ... (Canada), so that the rectification order was reversed, the Court stated (at paras. 25, 29-30, 36, TaxInterpretations translation): If the agreement is consistent with what the parties agreed to but simply produces unforeseen tax consequences, due to an error by the tax planners in the design of the tax planning, rectification cannot be granted. … The parties had not planned any specific entitlement [“prestation”] aimed at ensuring that Structures and the holding companies were connected throughout the 31 stages of the corporate reorganization of Structures. … … Mr. Côté, the tax specialist who conceptualized the reorganization, … affirmed that maintaining connectedness was not the object of the transaction, which was to crystallize as much CGD as possible.... ...