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

Example 2 (re the day the foreign currency is acquired – occurring on date of money order purchase) On April 12, 2017, a non-resident … invoiced a Canadian GST/HST registered recipient of a supply for $1,000 US, for a taxable supply made in Alberta that was subject to the GST at a rate of 5%. ... Acceptable exchange rate sources 13. … [A] person may use the exchange rate from: the source used for an actual conversion (that is, the source where the foreign currency was exchanged for Canadian dollars) the source the person typically uses for actual conversions a Canadian chartered bank the Bank of Canada the rate provided by the … CBSA … for purposes of converting the value for duty of imported goods Example 4 (regular use of a local U.S. bank for FX exchange) … [A U.S.] company regularly uses the services of a local American bank to exchange US currency for foreign currencies and vice versa. Since the company regularly uses the local bank to exchange currencies, the local bank is an acceptable exchange rate source Example 5 (database service not an acceptable source) The company … subscribes to a database service that tracks and reports currency exchange rates, including rates on the interbank market, rates set by the Bank of Canada, and average rates offered by Canadian chartered banks. ...

. … The exemption does not apply to other courses relating to English or French, such as courses intended to help students improve their command of English or French when it is their first language, nor does it apply to the supply of instruction in languages other than French or English. ... Operated test 23. … The CRA will consider a business to be operated primarily to provide instruction in languages if more than 50% of its total annual revenues are derived from fees/tuition for, or can be attributed to instruction in, language courses. … 26. … [I]f the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...

Accordingly, the Distributions, as payments of money in respect of the Partners' interests in the Limited Partnership, are financial services under paragraph (f) …. When the Partnership provides the payment of a Distribution to a Partner, the Partnership is making … an exempt supply … unless the supply is zero-rated …. ...

Based on the average retail price per meal at the university, the single amount paid by a student is sufficient to provide the student with at least 10 meals each week for the period of the plan ($7.25 × 10 meals × 34 weeks = $2,465). ...

The term “other body established by a government” is also found in other provisions …. ... Discussion of Category 1 An “other body established by a government” includes a body that a government creates in legislation (i.e., through statute and subordinate legislation such as regulations and Orders-in-Council) … [e.g.] the Ontario Energy Board was created under the Ontario Energy Board Act …. It should be noted that this category does not include a body that is incorporated pursuant to-the authority of a statute that provides the legal basis for and a scheme for incorporation e.g., … the Canada Corporations Act …. ...

Its reasoning: Based on … the operator … not hav[ing] an interest in the real property on which the MURC is situated, the operator does not meet the conditions set out in paragraph (a) of the definition of “builder.” ...

CRA News Release, “Bare trusts are exempt from trust reporting requirements for 2023,” 28 March 2024-- summary under Subsection 150(1.2) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2) Cancellation of bare trust reporting obligation for calendar 2023 In recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians, the Canada Revenue Agency (CRA) will not require bare trusts to file a … T3 return … including Schedule 15 (Beneficial Ownership Information of a Trust), for the 2023 tax year, unless the CRA makes a direct request for these filings. ...

26 August 2019 Comfort Letter- “Advantage”: Exclusion for Investment Management Fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) where RRSP or TFSA fees (described in s. 20(1)(bb)) are paid by the annuitant or holder [If] investment management fees of registered plans … are paid directly by the holder/annuitant using funds outside of the plan, the resulting indirect increase in the value of the plan assets might be viewed as an advantage … if one of the main purposes is to benefit from the tax-exempt status of the plan. Even so, we have no tax policy concerns with respect to the payment of investment management fees directly by the annuitant/holder of the registered plan. … Generally, the direct payment of fees results in either a net loss, or negligible gain, for the plan holder. We are therefore prepared to recommend … clarifi[cation] that the payment by a controlling individual (as defined in subsection 207.01(1)) of investment management fees that pertain to a registered plan does not constitute an advantage … [and] [s]pecifically … that paragraph (b) of the definition "advantage" in subsection 207.01(1) be amended [respecting 2018 and subsequent taxation years] such that it does not apply to payments by a controlling individual of a registered plan, not exceeding a reasonable amount, of fees described in paragraph 20(l)(bb) …. ...

This means that no interest will apply …. The deadline for businesses to file their returns is unchanged. … However … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th. ... Q.4 No automatic deferral for excise duties Excise taxes and duties are still required to be remitted by their prescribed due dates. … Decisions to waive interest are made on a case by case basis. ... Q.9 No payment of housing/general rebate rebate claims Only the GST/HST rebate applications filed electronically for … Point-of-Sale and Public service bodies with the CRA can be processed automatically unless they require client contact or additional review. ...

CRA responded: [T]he formula outlined in paragraph 254(2)(i) … makes reference to the “total consideration” … described in paragraph 254(2)(c) … [as] the sum of the consideration payable for the housing itself (that is, the purchase price of $250,000) and the consideration payable for any other taxable supply of an interest in the housing (that is, the assignment fee of $150,000). ... A [instead] were not a builder, his assignment of the agreement of purchase and sale would be an exempt supply … and the consideration for the exempt assignment would not be included in determining the “total consideration” as described in paragraph 254(2)(c). … ...