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

. … In this case the individual being sued is the recipient as he agreed to pay the suing lawyer…. ...

19 September 2015 STEP Roundtable, Q.5-- summary under Subsection 104(13.2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.2) late s. 104(13.2) designation to utilize capital loss carryback CRA accepts that if a trust has pushed out income to its beneficiaries in Year 1 and in, say, Year 3, realizes a non-capital or capital loss, it can amend its return for Year 1 to include income, which it previously had pushed out to its beneficiaries, in its income, thereby resulting in net income that can be offset by a loss carryback – and with the beneficiaries' returns then being reassessed to exclude the previous inclusion under s. 104(13). ...

. … For this reason, one is to assume that the expenses would need to be submitted to the insurance company before the amount can be considered by the Canada Revenue Agency…. ...

. … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

Eligible spin-offs-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) // www.cra-arc.gc.ca/tx/bsnss/tpcs/frgncrp-eng.html ">"Information for foreign corporations" 6 March 2012: Respecting the requirement in s. 86.1(2)(b) that the distribution consist only of shares, CRA states: If the shares distributed in the course of the spin-off had rights to purchase other shares attached to them, the corporation should confirm that the rights plan was established for bona fide business purposes other than to obtain a tax benefit. ...

26 February 2015 CBA Roundtable, Q.21-- summary under Qualifying Member Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(1)- Qualifying Member s. 186(1) does not deem use of property in commercial activity CRA indicated that s. 186(1) applied “only for the purpose of ITC calculations” and does not have the effect of deeming the holding company to be engaged in commercial activity – so that it would generally not qualify for the purposes of making a s. 156 election with a subsidiary so as to avoid having to charge GST on management fees. ...

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Section 13 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations, No. 2- Section 13 Public service body acquiring software programming services for use in two provinces Example 7 references a PSB that is charged at the Ontario rate of 13% on software programming services acquired by it for “use” 80% at its Ontario head office and 20% at one of its offices in PEI – and goes on to note that the PSB would be required to self-assess itself for the 2% higher PEI HST rate on the 20% portion for use in PEI, before then calculating its s. 259 rebate. ...

. … The person that is eligible to claim the ITC for the tax paid or payable on the property or service is usually the recipient. ...

CRA stated: We confirm that an electronic signature produced using […] or [a] similar device is acceptable for purposes of filing a GST/HST rebate application, provided the signature and any related electronic records exhibit the characteristics of reliability, integrity, and authenticity, as discussed in GST/HST Memorandum 15.2, Computerized Records. ...

CRA ruled that the rebate is financial assistance and does not reduce the consideration for the supply of the electricity – so that input tax credits or public service body rebate claims of the recipient are not reduced by the rebate amount. ...