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Technical Interpretation - External summary
19 August 2010 External T.I. 2009-0344111E5 F - Résidence Société Capital-Risque - Conv Can-France -- summary under Article 4
It should be noted that a VCC may still be taxed in France on its gains from the disposal of securities which have remunerated it for its contribution of ancillary activities, as well as on income realized in accordance with the company's objects but not coming from the portfolio, such as profits from the disposal of movable or immovable property, and subsidies, all as described … above. ...
Technical Interpretation - External summary
27 July 2010 External T.I. 2010-0364841E5 F - Questions relatives à une séparation -- summary under Paragraph 118(1)(b)
27 July 2010 External T.I. 2010-0364841E5 F- Questions relatives à une séparation-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) two separated spouses living under the same roof required to agree on which one claims the s. 118(1)(b) credit After indicating that it appeared that the correspondent was living separate and apart from the correspondent’s spouse notwithstanding their living under the same roof, CRA stated: [E]ither you or your spouse would be able to claim the wholly dependant person [“equivalent to spouse”] credit under paragraph 118(1)(b) in respect of one of your children, to the extent that the married or common-law partner credit under paragraph 118(1)(a) is not claimed and you were not supporting or dependent on your spouse at any time in the year …. ...
Technical Interpretation - External summary
28 June 2010 External T.I. 2009-0350241E5 F - Crédit d'impôt pour investissement du Québec -- summary under Paragraph 13(7.1)(f)
. … [T]he corporation is entitled to receive this credit for the purposes of paragraph 13(7.1)(f) when the conditions of the first paragraph of section 1029.8.36.166.43 of the TA are satisfied, that is, at the end of the taxation year in which it claims the credit. ...
Technical Interpretation - External summary
22 March 2011 External T.I. 2010-0391131E5 F - Gains ouvrant droit à pension - RPC/RRQ -- summary under Subsection 200(1)
. … [D]eductions for contributions to the Québec Pension Plan must therefore begin to be deducted from the first pay of the month following the month in which the employee reaches the age of 18 years and the amount to be shown in Box 26 of the T4 slip must be recognized from that same time. ...
Technical Interpretation - External summary
9 June 2010 External T.I. 2009-0342081E5 F - Associé déterminé -- summary under Specified Member
. … [T]he more Mr. X is involved in the management and/or day-to-day operations of the SENC, the less likely it is that Trust X will be considered a specified member within the meaning of subsection 248(1). ...
Technical Interpretation - External summary
28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Subsection 20(10)
. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ...
Technical Interpretation - External summary
21 April 2010 External T.I. 2009-0341711E5 F - Déduction pour gains en capital -- summary under Paragraph 110.6(14)(d)
Respecting the trust beneficiary scenario, CRA stated, before concluding that “the Act allows a beneficiary of a trust, who is a member of a partnership that disposes of QSBCSs, to benefit from the capital gains deduction under subsection 110.6(2.1) if the capital gain is designated by virtue of subsection 104(21.2): [G]enerally, subsection 104(2) provides that for the purposes of the Act “a trust shall … be deemed to be in respect of the trust property an individual….” ...
Technical Interpretation - External summary
28 June 2010 External T.I. 2010-0357081E5 F - Crédit d'impôt pour la rénovation domiciliaire -- summary under Paragraph (b)
. … If the move occurs after the eligible period, in this example in March 2010, the unit will not be an eligible dwelling of the individual or a qualifying relation of the individual since it will not have been ordinarily occupied during the eligible period. ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0357071E5 F - Crédit d'impôt pour l'achat d'une 1e habitation -- summary under Subparagraph (a)(i)
19 May 2010 External T.I. 2010-0357071E5 F- Crédit d'impôt pour l'achat d'une 1e habitation-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home- Paragraph (a)- Subparagraph (a)(i) given future intention test, there can be a gap between purchase and home becoming principal residence Can an individual otherwise satisfying the conditions claim the HBTC if the individual acquired a residence on December 15, 2009, but did not live in it before February 1, 2010 (and may have renovated it during that period) – and can there be a gap between the time of the home’s purchase and it becoming the individual’s principal place of residence? ...
Technical Interpretation - External summary
6 December 2016 External T.I. 2015-0589041E5 F - Frais médicaux payés d’avance - prepaid medical expenses -- summary under Subsection 118.2(1)
. … For example, where an individual chooses the period from January 1 to December 31, 2016…[i]f the…fees were paid on December 31, 2015, they would not be eligible for the METC computation for the 2016 taxation year…. ...