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
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Technical Interpretation - External summary
19 March 2003 External T.I. 2002-0151015 F - ALLOCATION DU COUT EN CAPITAL -- summary under Paragraph 16(e)
In that case, the vehicles must be reclassified, from that point onwards, in another Class …. ...
Technical Interpretation - External summary
21 March 2003 External T.I. 2002-0161115 F - ALLOCATION DE FIN DE CARRIERE -- summary under Earned Income
CCRA also indicated: [T]he reserve included in computing business income pursuant to subsection 34.2(5) for the taxation year subsequent to the year in which a taxpayer ceases to carry on business will not be included in earned income …. ...
Technical Interpretation - External summary
18 December 2003 External T.I. 2003-0021195 F - Etablissement Stable en Ontario -- summary under Subsection 400(2)
. … In this case, the facts submitted are clearly insufficient to allow us to conclude whether or not the XXXXXXXXXX office constitutes a fixed place of business for Canco. ...
Technical Interpretation - External summary
9 December 2003 External T.I. 2003-0032585 - Immeuble détenu par une succession -- summary under Paragraph (c.1)
Consequently … the estate may designate the portion of the property that you occupied as your principal residence since its acquisition. ...
Technical Interpretation - External summary
21 February 2000 External T.I. 2000-0004915 - FARMLAND-CONV. TO INVENTORY -- summary under Paragraph 45(1)(a)
" … [W]here a farmer, makes application for subdivision, then subdivides the farmland and proceeds to develop it and sell lots, it is our general view that the farmland would be considered to have been converted into inventory at the time of making application to the relevant authority for approval of a plan to subdivide the land into lots for sale. ...
Technical Interpretation - External summary
19 July 2018 External T.I. 2014-0551941E5 F - Déplacement effectué par un employé -- summary under Paragraph 6(1)(b)
After repeating its position that “personal travel includes travel between the employee's home and ‘regular place of employment’,” and noting that “regular place of employment” was described in T4130 as including “a client's premises when an employee reports there daily for a six month project” and “a client's premises if the employee has to attend biweekly meetings there,” and before noting that it could only make general comments, CRA stated: If the place of business of a client of the firm constitutes a "regular place of employment " for the auditor, the travel between the auditor’s residence and the place of business of that client is considered personal travel and is therefore not considered travel "in the performance of the duties of the employee’s office or employment". ...
Technical Interpretation - External summary
4 December 2018 External T.I. 2016-0670851E5 - Regular Places of Employment and Personal Travel -- summary under Paragraph 6(1)(b)
4 December 2018 External T.I. 2016-0670851E5- Regular Places of Employment and Personal Travel-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) scope of “regular place of employment" Respecting requested clarification as to when a particular work location is considered a regular place of employment for an employee, CRA stated: [T]ravel between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. ...
Technical Interpretation - External summary
26 May 2016 External T.I. 2014-0527251E5 F - Interest Deductibility -- summary under Subparagraph 20(1)(c)(ii)
Before concluding that the interest was deductible under s. 20(1)(c)(ii), CRA referenced its position in Folio S3-F6-C1, para. 1.65 that “where a note is issued to purchase and cancel (or otherwise redeem) shares, interest expense may be deductible under subparagraph 20(1)(c)(ii),” and then stated: In a situation as such described above where there is a capitalization of a portion of a corporation's accumulated profits as stated capital of the preferred shares of the capital stock of the corporation, the CRA is of the view that the "capital" attributable to the preferred shares for the purpose of applying the "fill the hole" concept … generally corresponds to the paid-up capital of the shares. ...
Technical Interpretation - External summary
14 May 2019 External T.I. 2017-0737571E5 - SAR plan with dividend equivalents -- summary under Subsection 6(14)
CRA went on to state: [S]ubsection 6(14) … will not apply to such a plan to provide partial relief from the SDA rules for the main component of the award. ...
Technical Interpretation - External summary
11 June 2019 External T.I. 2019-0795291E5 F - Tax on Split Income - 120.4(1) excluded amount -- summary under Related Business
B's child under s. 252(1)(c) – and they would not otherwise be related. ...