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Administrative Policy summary
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries" -- summary under Scientific Research & Experimental Development
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Administrative Policy summary
Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work - Allowable SR&ED Expenditures". -- summary under Scientific Research & Experimental Development
Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work- Allowable SR&ED Expenditures".-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 16. ("Constructive Importer Rules – Section 178.8") -- summary under Subsection 178.8(2)
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 16. ("Constructive Importer Rules – Section 178.8")-- summary under Subsection 178.8(2) Summary Under Tax Topics- Excise Tax Act- Section 178.8- Subsection 178.8(2) A resident registered corporation (Corporation A) entered into an agreement with a resident registered corporation (Supplier) for the purchase of a power facility the components of which were to be imported from abroad. ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services") -- summary under Section 16
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services")-- summary under Section 16 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 16 A GST/HST-registered Canadian law firm performs legal services, as a single, bundled supply, on behalf of a Canadian lender in a secured financing transaction, where the security for the loan is registered under the Personal Property Security Acts in five Canadian provinces against the borrower's tangible personal property, including inventory. ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ("Application of S. 10.1, Sch. VI, P. V – Service Related to Intangible Personal Property") -- summary under Section 10.1
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ... V – Service Related to Intangible Personal Property")-- summary under Section 10.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 10.1 A Canadian GST-registered supplier sells custom software that it has been using to perform a service electronically, with such supplies being made in Canada. ...
Administrative Policy summary
May 2019 CPA Alberta CRA Roundtable, ITA Session – Q.7 -- summary under Subsection 248(10)
May 2019 CPA Alberta CRA Roundtable, ITA Session – Q.7-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) “in contemplation of” can be backwards looking What factors would CRA typically review to assess whether certain transactions are part of the same series; and how important is it that transactions were carried out at, or around, the same time? ... Per … Copthorne …: ``… The fact the language of s. 248(10) allows either prospective or retrospective connection of a related transaction to a common law series and that such an interpretation accords with the Parliamentary purpose, impels me to conclude that this interpretation should be preferred to the interpretation advanced by Copthorne…`` The text and content of s. 248(10) have left open when the contemplation of the series must take place as nothing in the text specifies when the related transaction must be completed in relation to the series. ...
Administrative Policy summary
GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025 -- summary under Clause 6(2)(b)(i)(C)
Clause 6(2)(b)(i)(C) …and … 8(b)(i)(C) … further provides that if the supplier does not obtain a home or business address in Canada of the recipient in the ordinary course of its business, but in the ordinary course of its business the supplier obtains another address in Canada of the recipient, the supply is made in the province in which the address that is most closely connected with the supply is located. 54. [In this context] … there is no requirement for the address of the recipient to be an address at which the recipient is located. 55. The types of addresses that could fall under this … Rule … could include an address of the recipient such as a billing address. ...
Administrative Policy summary
Tax on split income – Excluded shares (CRA webpage) 10 July 2019 -- summary under Subparagraph (a)(i)
CRA indicated: [T]he cleaning products are incidental to the services, since they were used in providing the services [so that] the incidental goods amount … would not be subtracted from the service part of the gross business income i.e., 100% of its revenue would be services revenue. ... Example 6 (separate charges of deck construction company for labour and materials are respected) A corporation engaged in the design, construction and repair of decks supplies all materials and labour when constructing and repairing the decks – and for a fee, also designs decks and provides plans to customers who want to build the deck on their own. Gross business income of the corporation (2017): $200,000 made up as follows: Deck construction: $175,000: Materials $90,000 Labour $85,000 Deck repairs: $20,000: Materials $10,000 Labour $10,000 Deck design: $5,000 Gross business income for services: $100,000 ($200,000 − $90,000 − $10,000) Gross business income test: $100,000 ∕ $200,000 = 50% Since less than 90% of the business income from all activities of the corporation is for services, the condition in subparagraph 120.4(1)(a)(i) of the definition of excluded shares is met. ...
Administrative Policy summary
May 2019 CPA Alberta CRA Roundtable, GST Session – Q.18 -- summary under Subsection 273(4)
May 2019 CPA Alberta CRA Roundtable, GST Session – Q.18-- summary under Subsection 273(4) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(4) back-dated election generally permitted if the parties had been treating one as in place Joint venture participants, who had not made a joint venture election, purchased real estate collectively through a representative who was registered for GST/HST purposes. ... Generally, if the conditions of the … Election … have been met, and the parties have treated their transactions as if the election had been valid (which is supported by agreements/invoices) and the parties are otherwise compliant with the CRA, Audit will allow this election to be backdated. ...
Administrative Policy summary
Frequently Asked Questions – Temporary Wage Subsidy for Employers 30 March 2020 CRA Webpage -- summary under Subsection 153(1.02)
Frequently Asked Questions – Temporary Wage Subsidy for Employers 30 March 2020 CRA Webpage-- summary under Subsection 153(1.02) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.02) 1. Overview of wage-subsidy COVID-19 response The Temporary Wage Subsidy for Employers is a three-month measure that will allow eligible employers to reduce the amount of payroll deductions required to be remitted to the … CRA …. 2. ... This includes reducing remittances that may fall outside of the application period for the wage subsidy (after June 19, 2020). … 8. ...