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Technical Interpretation - External

4 March 2025 External T.I. 2025-1053731E5 - DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement

4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) Inconsistent Statement Unedited CRA Tags 87(4), 87(8), 87(8.4), 87(8.5). ... XXXXXXXXXX 2025-105373 Yannick Roulier March 4, 2025 Dear XXXXXXXXXX: Re: DOF Explanatory Notes on Subsections 87(8.4) & (8.5) Inconsistent Statement We are writing in reply to your email dated February 14, 2025, in which you suggested that a particular statement made in the Department of Finance’s explanatory notes seems to be inconsistent with a technical reading of the legislation. ...
GST/HST Ruling

18 February 2013 GST/HST Ruling 149984 - […] [Carrying on Business in Canada] – Requirement to be Registered

[TourCo] […] operates "tour packages" (as that term is defined in the ETA) […]. 3. […]. 4. ... You also provided us with the terms and conditions of the […] tours. […]. 12. The tours are generally described, in the […] brochure […], as guided tours that have [Employees] that are available throughout the tours, […]. 13. […] 14. ...
Current CRA website

Corporate Business Plan - In Brief 2000 | 2001 to 2002 | 2003

Corporate Business Plan- In Brief 2000 | 2001 to 2002 | 2003 Home | The CCRA Board of Management | Innovation at the CCRA | Our Strategic Foundation | Vision and Strategic Goals | Strategic Direction | Measuring our Performance | Our Investment | Need more information | Survey The 2000-2001 to 2002-2003 Corporate Business Plan marks a new beginning for our organization. ...
Miscellaneous severed letter

8 November 1989 Income Tax Severed Letter AC73828 - Integrated Sawmill & Pulpmill - M & P Deduction

8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. Paragraph l25.l(3)(a) of the Act defines M & P profit by reference to rules prescribed by regulation i.e. section 5200 and following of the Income Tax Regulations ("Regulations"). ...
Current CRA website

T4088 – Scientific Research and Experimental Development (SR&ED) Expenditures Claim – Guide to Form T661

Lines 151 to 157 Partnership information Refer to the " Partnerships " section of this guide. ... Example If out of five scientists and engineers engaged in SR&ED, one works solely on SR&ED projects and the remaining four devote only one-quarter of their working time to SR&ED, then line 632 = 1 + ¼ + ¼ + ¼ + ¼ = 2 full time equivalents (FTE)s. ... Medical and Health sciences Basic medicine 3.01.01 Anatomy and morphology (plant science under 1.06.08) 3.01.02 Human genetics 3.01.03 Immunology 3.01.04 Neurosciences 3.01.05 Pharmacology and pharmacy and medicinal chemistry 3.01.06 Toxicology 3.01.07 Physiology and cytology 3.01.08 Pathology Clinical medicine 3.02.01 Andrology 3.02.02 Obstetrics and gynaecology 3.02.03 Paediatrics 3.02.04 Cardiac and cardiovascular systems 3.02.05 Haematology 3.02.06 Anaesthesiology 3.02.07 Orthopaedics 3.02.08 Radiology and nuclear medicine 3.02.09 Dentistry, oral surgery, and medicine 3.02.10 Dermatology, venereal diseases, and allergy 3.02.11 Rheumatology 3.02.12 Endocrinology and metabolism and gastroenterology 3.02.13 Urology and nephrology 3.02.14 Oncology Health sciences 3.03.01 Health care sciences and nursing 3.03.02 Nutrition and dietetics 3.03.03 Parasitology 3.03.04 Infectious diseases and epidemiology 3.03.05 Occupational health Medical biotechnology 3.04.01 Health-related biotechnology 3.04.02 Technologies involving the manipulation of cells, tissues, organs, or the whole organism 3.04.03 Technologies involving identifying the functioning of DNA, proteins, and enzymes 3.04.04 Pharmacogenomics, gene-based therapeutics 3.04.05 Biomaterials (related to medical implants, devices, sensors) Other medical sciences 3.05.01 Forensic science 3.05.02 Other medical sciences 4. ...
GST/HST Ruling

19 January 2011 GST/HST Ruling 123253 - Services provided by [...] [Company A] to [...] [Company B]

19 January 2011 GST/HST Ruling 123253- Services provided by [...] [Company A] to [...] ... [Company A] [...] operates [...]. [Company A] is registered for the GST/HST. 2. On [mm/dd/yyyy], [...] entered into a [...] Agreement with [...] and on [mm/dd/yyyy] established a [...] ...
Current CRA website

Offshore Compliance Advisory Committee – Agenda – June 8, 2018

Offshore Compliance Advisory Committee Agenda June 8, 2018 Friday, June 8, 2018 9:00 a.m.- 4:30 p.m. ... Tax Gaps Presentation (T1 international) and follow up discussion on approach, assumptions, sensitivity analysis Mireille Éthier / André Patry / All 11:30 Lunch 12:15 7. ... Gina Jelmini / Johanne Charbonneau / All 15:45 9. Next steps / forward agenda All 16:00 10. ...
GST/HST Ruling

4 June 2012 GST/HST Ruling 136103 - s - Point-of-sale rebate entitlement – whether printed books – 6 products

The supply is a package which contains a […] children’s book entitled […] [Book A] and a […] toy […]. ... The book contains information about […] and has [#] pages. 2. The back of the book states: “Learn all […]. Then, play the […] game […]!” 3. In terms of printed space, the game takes only […] pages of the […] pages. ...
GST/HST Interpretation

4 July 2013 GST/HST Interpretation 144290 - [...] the availability of a [...] [GST/HST] new housing rebate

4 July 2013 GST/HST Interpretation 144290- [...] the availability of a [...] ... The Purchase Agreement indicates that Schedule A [...], Schedule B [...] and Schedule C [...] are part of this agreement. ... The statement of adjustments indicates a purchase price of $[...], GST of $[...], as well as a GST rebate of $[...]. ...
Conference

9 October 2009 Roundtable, 2009-0330081C6 F - Sens de " année " au paragraphe 74.5(2)

9 October 2009 Roundtable, 2009-0330081C6 F- Sens de " année " au paragraphe 74.5(2) Unedited CRA Tags 74.5(2) Principales Questions: Quel sens faut-il donner à l'expression " année donnée " au paragraphe 74.5(2) pour établir le montant des intérêts payables? ... Michel Lambert (613) 957-8968 October 9, 2009 2009-033008 ENDNOTES 1 AGENCE DU REVENU DU CANADA, interprétation technique 912556, " Meaning of Particuliar Year ", 21 octobre 1991. 2 AGENCE DU REVENU DU CANADA, interprétation technique 2008-0274221I7 (E), Meaning of " year " in 74.5(2), 16 avril 2008. 3 Al. 249(1)b) L.I.R. 4 CANADA REVENUE AGENCY, technical interpretation 912556, "Meaning of Particular Year", October 21, 1991. 5 CANADA REVENUE AGENCY, technical interpretation 2008-0274221I7 (E), Meaning of "year" in 74.5(2), April 16, 2008. 6 Par. 249(1)(b) of the ITA ...

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