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Administrative Policy summary
7 April 2022 CBA Roundtable, Q.7 -- summary under Subsection 191(1)
. … A substantial renovation is generally considered to have taken place where all or substantially all of the interior of a residential condominium unit has been removed or replaced and, upon completion, the renovated or altered unit is, or forms part of, a residential complex. c) CRA stated: Where a conversion occurs, the number of units the person is considered to have constructed or substantially renovated is a question of fact that depends on the work performed on each individual unit. d) CRA indicated that the only exemptions from the self-assessment rule in s. 191(1) were those in ss. 191(5) to (7). ...
Administrative Policy summary
7 April 2022 CBA Roundtable, Q.9 -- summary under Subsection 190(1)
However … since there is already a residential complex in the building, the Commercial Unit will never begin to be used as a residential complex in its own right. ...
Administrative Policy summary
Memorandum 8-3 - "Calculating Input Tax Credits" -- summary under Subsection 169(1)
. … 57. A revenue-based method should be used with caution ...
Administrative Policy summary
7 April 2022 CBA Roundtable, Q.19 -- summary under Subsection 181(2)
Similar consequences would attend the redemption of loyalty points by a customer in exchange for a free service provided by Bco or the dealer – except that, regarding Aco’s payment to Bco respecting the points redeemed by Bco, no ITC would be generated to Aco because s. 181(5)(c) would not be met. ...
Administrative Policy summary
CRA Webpage, "Notifiable transactions designated by the Minister of National Revenue," 15 August 2024 -- summary under Subsection 237.4(3)
CRA Webpage, "Notifiable transactions designated by the Minister of National Revenue," 15 August 2024-- summary under Subsection 237.4(3) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(3) Straddle transactions of FX-trading partnership (NT-2023-01) A taxpayer buys an interest in a partnership which, immediately prior thereto, had realized the gain legs on straddle transactions in FX forward contracts (with such gain allocated to the selling partner) – and with the loss legs then being realized and allocated to the taxpayer. ...
Administrative Policy summary
IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa" 16 September 19864 -- summary under Computation of Profit
. … Computation where depreciable property converted to inventory 18. ...
Administrative Policy summary
GST/HST Notice 287 "CRA Administrative Positions on the Application of the Import Rules for Financial Institutions to Reinsurance Contracts" January 2015. -- summary under Loading
. … The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ...
Administrative Policy summary
GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001 -- summary under Business
GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Appendix C … General distinction between a regular business and an adventure General approach 3. ...
Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 263(3)
Mutual fund dealers whose clients invest with other FIs 6.2 … Subsection 263(3) of the ITA makes clear that a financial account includes a client-name account maintained by a person or entity that is authorized under provincial law to engage in the business of dealing in securities or any other financial instrument or to provide portfolio management or investment advising services. ...
Administrative Policy summary
Dual-purpose payments -- summary under Subsection 6(3)
. … Example 1: inclusion of signing bonus subject to repayment As an inducement to a prospective employee to accept an employment offer, an employer agrees to make a payment when the individual signs the employment contract. ...