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

12 October 1995 External T.I. 9512485- PARTITION OF ACCOUNTS RECEIVABLES & OTHER FUNGIBLES. ... Principal Issues: APPLICATION OF 248(20) & 248(21) WHERE THE SUBJECT PROPERTY IS ACCOUNTS RECEIVABLES INVENTORY AND OTHER LIKE PROPERTY COMPRISED OF NUMEROUS INDIVIDUAL PROPERTIES? ...

14 November 2002 External T.I. 2002-0136625- Compound interest & thin capitalization Unedited CRA Tags 18(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Yours truly, Olli Laurikainen for Director International & Trusts Division Income Tax Rulings Directorate ...

1 May 2018 External T.I. 2018-0743031E5- Work in progress / Travaux en cours 1 May 2018 letter to APFF, 2017-0709101E5 F is essentially the same and is summarized by us at that node Unedited CRA Tags 34, 10(1), 10(4)(a) Principal Issues: 1) Several questions regarding work in progress cost determination. 2) How should the value of a professional’s work in progress be determined where the work is performed on a contingency basis? / 1) Plusieurs questions portant sur la détermination du coût des travaux en cours. 2) Comment détermine-t-on la JVM des travaux en cours résultant d’une entente mettant en cause des honoraires conditionnels? ... It may, in some cases, be nil. / 1) La détermination du coût est une question de fait. ...

18 April 1996 External T.I. 9608805- BED & BREAKFAST, QUALIFIED INVESTMENT Unedited CRA Tags 146(1) 4900(12) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... In any case, the determination of whether a bed & breakfast operation is an active business is a question of fact. In determining whether the operation of a bed & breakfast by a corporation is an active business, the number and kind of services it provides is the dominant factor. ...

30 March 1994 External T.I. 9330105- LIFE ESTATES & REMAINDER INTERESTS IN REAL PROPERTY Unedited CRA Tags 43.1 70(5) 70(6) 70(9) 73(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... A's will a Life Estate in farmland is conveyed to his spouse & the Remainder Interest to the children. ... Subsections 70(6), 70(6.2) & 70(5) may apply depending on the facts. ...

13 November 2013 External T.I. 2012-0462421E5- CPP & EI tax credit CRA Tags 118.7 Principal Issues: Where an individual has been issued a T4 with employment income reported in error, can the CRA disallow the individual's CPP and EI tax credit claimed, after an amended T4 is issued? ... In computing this tax credit, paragraph 118.7(a) of the ITA states, in part, "…the total of all amounts each of which is an amount payable by the individual as an employee's premium for the year under the Employment Insurance Act, …" and paragraph 118.7(b) states, in part, "…the total of all amounts each of which is an amount payable by the individual for the year as an employee's contribution under the Canada Pension Plan…". ...

10 January 2011 External T.I. 2010-0365421E5- Maternity & Parental Leave for Self Employed Unedited CRA Tags 96(1); 103(1.1); paragraph 2 Partnership Act [RSBC 1996] Principal Issues: How does a general partner show no self-employed income from a [50/50] general partnership during the benefit period under the [new] initiative "Employment Insurance Benefits for Self-Employed People (EIBforSEP)"? ... Paragraph 2 of the Partnership Act [RSBC 1996] CHAPTER 348 defines Partnership as: "... the relation which subsists between persons carrying on business in common with a view of profit. ...

11 July 2007 External T.I. 2006-0216491E5- 75(2) & CCA limitation on rental income Unedited CRA Tags 1100(11)(a) Principal Issues: When 75(2) applies to attribute rental income earned by an alter ego trust to an individual who also earns income from rental properties owned by him directly, is the CCA limited to the rental income earned on all the property or are there separate CCA limitations for the property held by the alter ego trust and for the property held by the individual? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

29 June 2006 External T.I. 2006-0172341E5- Motor Vehicle Allowance & SBI Reimbursement Unedited CRA Tags 6(1)(b)(vii.1) 6(1)(b)(xi) 7306 (ITR) Principal Issues: Whether a reimbursement of an employee's supplementary business insurance (SBI) will render the payment of a motor vehicle allowance unreasonable for the purposes of subparagraph 6(1)(b)(vii.1) of the Act and cause the allowance to be a taxable benefit for the employee recipient. ... Yours truly, Randy Hewlett For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

17 October 2005 External T.I. 2005-0136781E5- Scholarship, Tuition, & Education Tax Credits Unedited CRA Tags 56(1)(n) 56(3) 118.5(1) 118.6(2) Principal Issues: 1) Can a scholarship exemption be obtained where employment ends, and the employee receives an amount from their employer termed a "retraining allowance", which is paid directly to a school outside Canada for a one-month ESL teacher training course? ... In certain situations, a taxpayer may be able to claim a tuition tax credit, and / or an education tax credit in respect of taxable employer-paid tuition. ...