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Administrative Policy summary
28 February 2019 CBA Roundtable, Q.4 -- summary under Subsection 281.1(2)
CRA responded: As indicated … Memorandum 16-5 [para. 33] VDP applicants are required to submit information for the four calendar years before the date the application is filed for applications under Category 1 or Category 2. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.6 -- summary under Subsection 281.1(2)
. … [T]the NVCC is currently responding to requests for call-backs promptly. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.12 -- summary under Agency
. … [T]here are three essential qualities that help in determining whether a person is acting as agent in making a transaction on behalf of another person. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.22 -- summary under Subparagraph 7(a)(ii)
Since s. 256.1 only referenced ss. 6.1 and 6.11, DeveloperCo was not entitled to a rebate under s. 256.1 for the HST charged to it on the development costs borne by it – notwithstanding that the transactions generated fully-taxable revenues from the sublease purchasers. ...
Administrative Policy summary
4 September 2019 Comfort Letter - Principal Residence Exemption for Trusts -- summary under Clause (c.1)(iii.1)(B)
Finance stated that it would recommend an amendment (effective for taxation years beginning after 2016) to: Allow … an inter vivos trust for the benefit of an individual who is DTC-eligible to be eligible to claim the principal residence exemption as long as certain conditions are met. ...
Administrative Policy summary
27 February 2020 Report of the Quebec Ombudsman entitled "“So that taxpayers’ rights are upheld in payment arrangement proposals with Revenu Québec” -- summary under Subsection 169(3)
The report found that it was abusive and improper for the ARQ to reassess without an adequate evidentiary foundation capable of surviving judicial scrutiny – and that, in such instances, the reassessment should be dropped. ...
Administrative Policy summary
Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021 -- summary under Subsection 153(1.1)
. … If a Canadian resident employee of a non-resident entity is forced to perform their employment duties in Canada on an exceptional and temporary basis as a result of the Travel Restrictions and that employee has been issued a letter of authority applicable to the tax year including that period, the letter of authority will continue to apply and the withholding obligations of the non-resident entity will not change in Canada as long as there are no changes to the withholding obligations of the non-resident entity in the other jurisdiction. ...
Administrative Policy summary
Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Paragraph (a)
However, there are some exceptions and certain corporations that are exempt from tax can still be eligible …. ...
Administrative Policy summary
Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Subparagraph (d)(ii)
Eligible employers who … on March 15, 2020 employed one or more individuals and allowed a third party with a business number to make payroll remittances on their behalf, through the third party’s account, will need to register for their own payroll program account. ...
Administrative Policy summary
2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4 -- summary under Paragraph 153(1)(a)
2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no dispensation from source deductions for non-resident employers whose employees work from Canada due to COVID travel restrictions If an individual is not ordinarily resident in Canada, but is in Canada due to Travel Restrictions or otherwise due to public safety concerns relating to COVID-19, and works remotely (for their non-resident employer) from Canada, would the employer, if it has no Canadian ties, now be subject to withholding obligations in Canada – including in the situation where it did not consent to this Canadian nexus? ...