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Administrative Policy summary

IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences" -- summary under Class 14

Where renewal or extension periods are considered part of the life of the property under the criteria set out in 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ...
Administrative Policy summary

8 July 2013 Interpretation Case No. 145134 -- summary under Section 181.1

. [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...
Administrative Policy summary

Taxable Supplies - Special Cases [CRA website] -- summary under Subsection 153(1)

. Tips and gratuities …A tip or gratuity that is freely given by a customer, for example, cash not recorded on a bill, is not subject to the GST/HST. ...
Administrative Policy summary

2 December 2014 CTF Roundtable, Q. 9 -- summary under Paragraph 95(6)(b)

However, paragraph 95(6)(b) could still apply in other contexts such as… the manipulation of a taxpayer's participating percentage in a controlled foreign affiliate. ...
Administrative Policy summary

31 October 2011 Interpretation Case No. 132880 -- summary under Financial Service

In such a case, there must be a direct and clear connection between the payment made to the Dealer (lump-sum or periodic) and the services provided in relation to the initial sale of the […] Shares to the Client. ...
Administrative Policy summary

New position on private health services plans - Questions and answers 25 November 2015 -- summary under Subparagraph 6(1)(a)(i)

. $70 relates to coverage for prescription drugs that an employee lawfully buys, as prescribed by a medical practitioner and recorded by a pharmacist;…$20 relates to coverage for dental services paid to a dentist;…$8 relates to coverage for medical tests such as electrocardiograms, urine analysis, and x-rays; and…$2 relates to coverage for non-prescription vitamins. ...
Administrative Policy summary

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)" -- summary under Paragraph 217.1(1)(b)

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"-- summary under Paragraph 217.1(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 217.1- Subsection 217.1(1)- Paragraph 217.1(1)(b) Ss. 132(2) and (3) rules do not apply for purposes of s. 217.1(1)(b)(i) Qualifying taxpayer The reference to being resident in Canada in the definition of "qualifying taxpayer" does not include a non-resident with a permanent establishment under subsection 123(1) in Canada where that person is deemed under subsection 132(2) to be resident in Canada with respect to activities of the person carried on through the establishment. ...
Administrative Policy summary

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)" -- summary under Paragraph 217.1(2)(a)

. Example 3 Data processing services were performed outside Canada by a foreign parent corporation for the benefit of a qualifying taxpayer resident in Canada in the qualifying taxpayer's Canadian activities. ...
Administrative Policy summary

25 July 2014 Interpretation 158278 -- summary under Subsection 167(1)

25 July 2014 Interpretation 158278-- summary under Subsection 167(1) Summary Under Tax Topics- Excise Tax Act- Section 167- Subsection 167(1) lease is given by franchisor subsidiary to franchisee In finding that the grant of a franchise by the Franchisor to a new Franchisee respecting a specific site qualified as the supply of a business that was established by the supplier (the Franchisor) notwithstanding that the Franchisor did not directly supply real estate to the franchisee and the site instead was subleased by a subsidiary of the Franchisor to the Franchisee, CRA stated: Real property, whether purchased or leased, is normally required to carry on a food restaurant store/business. ...

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