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Conference summary

21 January 2016 Roundtable, 2016-0624811C6 F - Employee Assistance Program -- summary under Subparagraph 6(1)(a)(iv)

. [T]he services of the employee assistance program that are counseling or advice respecting areas other than those specified in clauses (A) and (B) of subparagraph 6(1)(a)(iv), would not come within the exception provided by paragraph 6(1)(a)(iv). ...
Conference summary

26 May 2016 IFA Roundtable Q. 3, 2016-0642111C6 - PUC of Shares of a FC Reporter -- summary under Canadian Tax Results

Shareholder would have to maintain that PUC balance in for the purposes of determining its CTRs. ...
Conference summary

7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F - Changement partiel d’usage - immeuble locatif et résidentiel -- summary under Paragraph 45(1)(c)

. In the described situation, although each of the building's units was subject to a change of use in Year 11, the relation between the use regularly made by the taxpayer of the property for gaining or producing income and the use regularly made of the property for other purposes did not change during the year. ...
Conference summary

7 October 2011 Roundtable, 2011-0408251C6 F - REER, règle d'attribution, retenues à la source -- summary under Subsection 146(8.3)

[T]he deductions [under s. 153(1)(j)] are made from the lump sum payment and designated as being for the account of the person receiving the amount, being the RRSP annuitant. ...
Conference summary

8 October 2010 Roundtable, 2010-0373221C6 F - Paid-up capital -- summary under Subsection 245(4)

. The CRA has already concluded in some of these types of cases that avoidance transactions are caught by subsection 245(4) and that the general anti-avoidance rule applies. ...
Conference summary

8 October 2010 Roundtable, 2010-0373691C6 F - T4A et T5018 - Honoraires -- summary under Subsection 238(2)

. The GST, HST, QST or provincial tax portion, if any, of the amount paid should not be reported on the T4A slip since it is not an amount under subsection 153(1) and is not required to be included in computing the recipient's income under the Act. ...
Conference summary

8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Subsection 246(1)

. [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Conference summary

8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Paragraph 12(1)(x)

. [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Conference summary

29 November 2016 CTF Roundtable Q. 11, 2016-0669761C6 - Computation of Earnings for LLCs -- summary under Subparagraph (a)(iii)

LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) earnings- s. ...
Conference summary

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F - Individuals separated living under the same roof -- summary under Cohabiting Spouse or Common-Law Partner

. Where a taxpayer and the taxpayer’s ex-spouse or former common-law partner state that they are living at the same address, but consider themselves as merely roommates from the date of separation, the following documents may support a request for validation: Divorce document; A court order or a legal separation agreement that sets out legal details of the arrangements for the individuals, child custody and provision for child support; Other legal documents; Mortgage documents showing the assumption of the entire mortgage by one of the parties and the effective date of the change; Proof of individual vehicle loans indicating the effective date of the change, if applicable; Proof of automobile insurance for each former spouse or common-law partner indicating the effective date of the change (from family to individual); Proof of individual medical insurance indicating the effective date of the change or the date the spouse or common-law partner was removed from the client's file; Individual credit card statements indicating the effective date of the change, if applicable; Letter from an independent third party, supplemented by persons in authority, attesting that the two individuals live at the same address but live separate and apart and no longer appear as a couple since a certain date. ...

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