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Miscellaneous severed letter
14 May 1993 Income Tax Severed Letter 9313025 F - Acquisition and Disposition — Property — General
14 May 1993 Income Tax Severed Letter 9313025 F- Acquisition and Disposition — Property — General Unedited CRA Tags 54(c) 248(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Conference
19 November 2021 Roundtable, 2021-0914351C6 - 2021 TEI Conference – Q3(b)(i) – Form T2200
19 November 2021 Roundtable, 2021-0914351C6- 2021 TEI Conference – Q3(b)(i) – Form T2200 Unedited CRA Tags 8(1)(i)(iii), 8(2), 8(10), 8(13), 67 Principal Issues: How the employer should complete the answers to Question 10 on Form T2200 in the case where an employee has the option to work from home and that time is not tracked by the employer? ...
Technical Interpretation - External
21 April 1997 External T.I. 9707215 F - % coproduction differe % cout production
21 April 1997 External T.I. 9707215 F- % coproduction differe % cout production Unedited CRA Tags 125.4 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principales Questions: 125.4- % coproduction differe % participation depense Position Adoptée: De façon générale, le CI pour une société admissible correspond à 25% de sa "dépense de main-d'oeuvre admissible". ...
News of Note post
In concluding that there had been no disposition of the debt, he found that of the “four fundamental terms of a debt obligation, i.e., the identity of the debtor, the principal amount, the amount of interest and the maturity date” identified in General Electric Capital, “ the only term that was significantly different in respect of the Post-Auction Debt … was the amount of interest.” ... The key passage appears to be the following: [S]ubparagraph (b)(i) of the [s. 248(1)] definition of “disposition” … states that “‘disposition’ of any property … includes … any transaction or event by which, … where the property is a … mortgage, … the property is in whole or in part redeemed, acquired or cancelled….” … Thus, by reason of the foreclosure and the judicial sale, the Mortgage was cancelled. ... The Queen 2021 TCC 33 under s. 18(1)(b) – capital loss v. loss – debt, s. 248(1) – disposition, s. 171(1), s. 9 – timing, and General Concepts – Evidence. ...
GST/HST Ruling
26 September 2014 GST/HST Ruling 156693 - AND INTERPRETATION – […] [Is a supply made by [the Charity] a service]
According to […], “[the Corporation] is the independent, non-profit organization that […]. [The Corporation] is independent from both the government and […].” 4. ... Schedule 1 to Program #2 Master Agreement indicates that the Charity is to deliver a […] service […] on behalf of the Corporation. ...
Excise Interpretation
3 January 2003 Excise Interpretation 42701 - Tariff Classification: " " Brought in Under Classification 2403.91.10 Not Subject to Customs Duty Equivalent to Excise Duty
3 January 2003 Excise Interpretation 42701- Tariff Classification: " " Brought in Under Classification 2403.91.10 Not Subject to Customs Duty Equivalent to Excise Duty Unedited CRA Tags ETA 23(2) XXXXX XXXXX XXXXX XXXXX Case: 42701January 3rd, 2003 Dear XXXXX This letter is in response to your email XXXXX concerning the importation of a product known as XXXXX and your request for a ruling on the tariff classification of this product. ... Sawab Nekiar, of the Customs Branch's Tariff Division, confirmed that XXXXX are classified under tariff item 2403.91.10 as "homogenized" or "reconstituted" tobacco "... suitable for use as wrapper tobacco. ...
Miscellaneous severed letter
22 May 1992 Income Tax Severed Letter 9214997 - Old at-risk rules — administrative position — Signum case
22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...
TCC (summary)
CRL Engineering Ltd. v. The Queen, 2019 TCC 65 (Informal Procedure) -- summary under Scientific Research & Experimental Development
The Queen, 2019 TCC 65 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development development of custom software qualified as SR&ED The taxpayer, which was an engineering firm specializing in developing public transit related technology, engaged in a project to develop its web‑based system using algorithms and GPS data to provide accurate real‑time data for predicting the arrival time of public transit buses. In finding that the taxpayer satisfied the five-factor test in Northwest Hydraulic Smith J stated (at paras 19, 21, 22, 25, 27, 28): [T]he objectives which the Appellants sought to achieve were sufficiently uncertain during the subject years. … [T]he Appellant’s Project was much more than “quality control or routine testing (…)” excluded by paragraph (f) of the Act, and … there was a “technological risk or uncertainty”. ... I … find that Appellant applied the scientific method and that its activities were structured to remove a technological uncertainty through the formulation and testing of its hypothesis. … [P]aragraph (d) of the definition of SRED includes “work undertaken for the purpose of achieving technological advancement for the purpose of creating new, or improving existing, materials, devices, products or processes, including incremental improvements thereto”. ...
Current CRA website
Appendix A – Data elements – TFSA individual electronic record
Required identification data for a TFSA individual electronic record TFSA Identification Data Comments Business number (BN) 15 alphanumeric characters – 9 digits – RZ – 4 digits. ... Total holder transfer in – Marriage breakdown – Fair market value Enter the total of all transfers in. Report type code Original = O Amendment = A Cancelled = C An amended return cannot contain an original slip. ...
Technical Interpretation - External
15 December 2006 External T.I. 2006-0182471E5 F - Intérêts " explicitement identifiés "
15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés " Unedited CRA Tags 12(1)c) Principales Questions: Demande de précision concernant la position administrative de l'Agence du revenu du Canada énoncée dans les Nouvelles techniques no 30 où cette dernière utilise l'expression " intérêts explicitement identifiés ". ...