Search - 司法拍卖网 人民法院
Results 581 - 590 of 79206 for 司法拍卖网 人民法院
Technical Interpretation - External summary
15 March 2019 External T.I. 2018-0766021E5 - Obligation to prepare T4A slips -- summary under Payment & Receipt
15 March 2019 External T.I. 2018-0766021E5- Obligation to prepare T4A slips-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt the payer is the person who has discretion and control over the funds A Canadian university agreed with a (perhaps, foreign) Ministry to apply funding received by it to pay the tuition of and a monthly stipend to trainees who were accepted into a University program. ...
Technical Interpretation - External summary
7 November 2022 External T.I. 2022-0926091E5 - Transfer of UK DB pension benefits to a UK SIPP -- summary under Payment & Receipt
7 November 2022 External T.I. 2022-0926091E5- Transfer of UK DB pension benefits to a UK SIPP-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt doctrine applied to direct payment from one UK pension plan to UK individual pension plan After a UK resident (under age 55) became resident in Canada, the commuted value of the individual’s member benefits under a UK defined-benefit pension plan was transferred directly to a UK self-invested personal pension plan (SIPP) of which the individual was the sole beneficiary. ...
Ruling summary
2023 Ruling 2023-0964601R3 - Loss consolidation arrangement -- summary under Payment & Receipt
2023 Ruling 2023-0964601R3- Loss consolidation arrangement-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in-house re-circulating daylight loan used to fund a loss-shifting transaction CRA ruled on routine transactions between two Lossco subsidiaries and one Profitco subsidiary of an immediate Canadian parent company involving Lossco loans to the Profitco and Profitco subscriptions for Lossco cumulative preferred shares. ...
Scraped CRA Website
T2 Corporation – Income Tax Guide – Chapter 5: Page 5 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 5: Page 5 of the T2 return On this page... ... For details, see Line 628 – Additional deductions – credit unions. The reduction also does not apply to income earned from a personal service business or to a corporation that was, throughout the year, an investment corporation, a mortgage investment corporation, or a mutual fund corporation. ...
Technical Interpretation - External
15 November 2006 External T.I. 2006-0190041E5 F - Biogas / Codigestion Process / Produced for Sale
15 November 2006 External T.I. 2006-0190041E5 F- Biogas / Codigestion Process / Produced for Sale Unedited CRA Tags Schedule II 43.1 43.2 Principal Issues: In a given fact situation, where the taxpayer produces biogas through a digester using a codigestion process (manure and other substances) and where the biogas production is purified into methane in part for sale, whether (1) the digester is property that could be included in class 43.1? ... En outre, ce matériel admissible acheté avant 2012 sera inclus dans la nouvelle catégorie donnant droit au taux de DPA de 50 %. ... Vos questions Votre première question est de savoir si le " digesteur " utilisé dans le Projet pour produire du biogaz par le procédé de "co-digestion" pourrait être considéré un bien de la catégorie 43.1 de l'annexe II du Règlement? ...
TCC (summary)
Sass Manufacturing Ltd. v. MNR, 88 DTC 1363, [1988] 1 CTC 2524 (TCC) -- summary under Scientific Research & Experimental Development
MNR, 88 DTC 1363, [1988] 1 CTC 2524 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer's appeal failed with respect to the deduction of expenses it incurred in manufacturing a machine in accordance with the engineering design and detailed drawings of a customer not only because the taxpayer had no right to the results of its research and investigation but also because the evidence fell "far short of establishing the existence of any systematic investigation or search carried out in a field of technology by means of experiment or analysis" (p. 1371). ...
FCA (summary)
Blue Wave Seafoods Inc. v. Canada, 2006 DTC 6155, 2006 FCA 81 -- summary under Scientific Research & Experimental Development
Canada, 2006 DTC 6155, 2006 FCA 81-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The Tax Court judge had committed no reviewable error in finding that in the last two taxation years under review, there was no longer any remaining scientific or technological uncertainty being addressed by the taxpayer in developing a commercial silver hake operation, so that related expenditures for those years did not qualify as SR&ED. ...
TCC (summary)
116736 Canada Inc. v. R., 98 DTC 1816, [1998] 3 CTC 2679 (TCC) -- summary under Scientific Research & Experimental Development
., 98 DTC 1816, [1998] 3 CTC 2679 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Before finding that the taxpayer had been engaged in qualifying SR&ED, Archambault TCJ. noted (at p. 1821) that the Act and Regulations "do not require that... written reports be produced in order for a taxpayer to qualify for the deduction of such expenditures: it is possible to adduce evidence by way of oral testimony". ...
Decision summary
Progressive Solutions Inc. v. The Queen, 96 DTC 1232 (TCC) -- summary under Scientific Research & Experimental Development
The Queen, 96 DTC 1232 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Archambault TCJ. accepted the evidence of the taxpayer's expert witness that the development by the taxpayer of a program improved an existing computer process (enabling the taxpayer to produce more efficient high-quality software products) and was the result of systematic investigation (notwithstanding very little documentary evidence of such investigation). ...
TCC (summary)
C W Agencies Inc v. The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393 -- summary under Scientific Research & Experimental Development
The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Bonner T.C.J. accepted (at p. 2382) the evidence of the Crown's expert that the cost incurred by a lottery ticket marketer in developing an information system employing object-oriented architecture did not represent SR&ED because "the project used commercially available products and services, and current information systems development methodologies and practices throughout". ...