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

See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. V, No. 3, pp. 21-23 (April 1991), at p. 22., which states in respect of “Intercorporate Transactions” (in part): … [A]s an administrative concession, Revenue Canada stated that it would not apply the anti-avoidance rule in section 155 to any of the transactions between the various corporations, in order that the transactions could be completed for nil or nominal consideration. ...

. … If an attempt is made to remedy the [described] situation by obtaining an amended invoice in compliance with the disclosure requirements, then the CRA will accept the amended invoice as supporting documentation. With respect to the letter from the supplier … [p]aragraph (h) … includes “any other document validly issued or signed by a registrant in respect of a supply made by the registrant on which GST/HST is paid or payable”. ...

Example showing dealer responsibility for nominee-name accounts and dealer/fund duty division re client-name accounts 5.15 … Example – Identification and reporting on an interest in a fund Two U.S. residents, Investor A and Investor B, seek to invest in Mutual Fund ABC (referred to in this example as the "Fund"). ...

The value of all of the FI’s business inputs other than non-attributable inputs are properly allocated between the taxable and exempt supplies made by it as follows: Inputs for taxable supplies Inputs for exempt supplies Exclusive inputs $31,000 $1,282,500 Direct inputs that are tracked $500,000 $4,471,200 Direct inputs allocated using causal allocation where tracking was not possible $171,800 $1,811,600 Total $702,800 $7,565,300 Excluded inputs $150,000 $525,500 Total including excluded inputs $852,800 $8,090,800 The FI calculates that 8.5% [$702,800 ÷ ($702,800 + $7,565,300)] of the services is for the purpose of making taxable supplies for consideration, and claims 8.5% of the GST on the invoice of the service provider as an ITC. ...

After indicating that “one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership … to any third party at the Builder’s request (for example, to the Home Buyer …),” CRA stated: [P]rovided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. ...

. … There are no provisions … to exempt the supply of paramedical services. … The fact that a paramedic may perform certain services on the delegated authority of a physician does not change the nature of the supply. ...

If the taxpayer cannot demonstrate to the CRA’s satisfaction the absence of retroactive tax planning, base erosion and profit shifting strategies, or double non-taxation, the auditor will … recommend the request not be accepted …. ... Therefore, in order for a downward transfer pricing adjustment to be considered appropriate, repatriation must be carried out within 90 days of signing a repatriation agreement (see … TPM-02R ….) 27. ... Appendix A – Examples Example of double non-taxation being addressed through foreign reporting or under MAP 3. ...

The volunteer paid $200 plus $26 in HST ($200 × 13%) for the car rental. ... The tax the charity is deemed to have paid in respect of the supply is equal to A × B where A is $26 – that is, the tax paid by the volunteer, B is 40% which is the lesser of 40% – that is, the percentage of the cost to the volunteer that was reimbursed, and 40% – that is, the extent expressed as a percentage to which the rental of the car was acquired for use in relation to activities of the charity. Therefore, the tax deemed paid by the charity for the car rental is equal to $10.40 ($26.00 × 40%). ...

All levels of such music lessons are exempt and they are not subject to the immediate mandatory prerequisite requirements … in paragraph 9(c) …. ...

New policy on “university” As a result of … Alexander College … a “recognized degree-granting institution” will now include a college or similar organization that is authorized by a province under provincial legislation or a governmental body in a foreign entity’s home jurisdiction to grant a degree where degree is defined in the applicable legislation to include an academic achievement at the associate level or higher. ...