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Technical Interpretation - External summary

31 May 2016 External T.I. 2016-0642011E5 - Functional currency election and partnerships -- summary under Subsection 229(1)

. Separate T5013 slips in Canadian dollars must be prepared by the partnership and provided to the non-electing partner(s) but these slips are not to be filed with the Canada Revenue Agency. ...
Conference summary

10 June 2016 STEP Roundtable Q. 3, 2016-0634891C6 - Estate beneficiary of IV Trust -- summary under Graduated Rate Estate

CRA noted that the graduated rate estate definition requires that an estate must be a testamentary trust, whose definition requires that no property have been contributed to the trust otherwise than by an individual on or after the individual’s death and as a consequence thereof so that the property contributed to the estate, as the beneficiary of the inter vivos trust, causes the estate to fail as a GRE. ...
Conference summary

10 June 2016 STEP Roundtable Q. 13, 2016-0645811C6 - Filing Obligation for 75(2) trust -- summary under Subsection 75(2)

10 June 2016 STEP Roundtable Q. 13, 2016-0645811C6- Filing Obligation for 75(2) trust-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) no return filing obligation if property of s 75(2) trust not income-generating Reg. 204(1) provides that a trustee having control of or receiving income, gains or profits must file an information return so that even though the property of the trust is subject to s. 75(2) so that its income is attributed to another person and the trust itself will have not tax payable, it still must file the T3 return. ...
Technical Interpretation - External summary

14 June 2012 External T.I. 2012-0443711E5 F - RAP - Annulation de la vente de l'immeuble -- summary under Effective Date

14 June 2012 External T.I. 2012-0443711E5 F- RAP- Annulation de la vente de l'immeuble-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date subsequent court-ordered voiding of home purchase did not retroactively void satisfaction of the HBP conditions at home purchase time In confirming that a judgment declaring a sale of a home to be void would not affect the operation of the HBP rules where the home in question was acquired under an HBP, CRA stated: Eligibility for withdrawing funds from an RRSP under the HBP is not affected by the occurrence of subsequent events. ...
Technical Interpretation - Internal summary

17 May 2012 Internal T.I. 2012-0437001I7 F - Price Adjustment Clause -- summary under Effective Date

. Furthermore, nothing in the wording of section 85 allows the CRA to require a taxpayer and a taxable Canadian corporation to file an election or an amended election. ...
Technical Interpretation - External summary

27 June 2012 External T.I. 2012-0440721E5 F - Compte de gestion de santé -- summary under Salary Deferral Arrangement

27 June 2012 External T.I. 2012-0440721E5 F- Compte de gestion de santé-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement conversion of future bonus into PHSP is taxable 2011-0426571C6 indicated that “the allocation of a future bonus to a HCSA [health care spending account] should be taxed as employment income because the allocation of a bonus to obtain additional flex credits in a HCSA is an allocation of foregone cash remuneration and should be subject to tax. ...
Technical Interpretation - External summary

17 April 2012 External T.I. 2012-0440931E5 F - Crédit d'impôt pour frais médicaux -- summary under Paragraph 5700(i)

In addition the Theracycle 200 motorized stationary bicycle was not designed "exclusively" to assist with walking. ...
Technical Interpretation - External summary

5 January 2016 External T.I. 2015-0568911E5 F - MRC - Revenu d’entreprise -- summary under Paragraph 149(1)(d.5)

CRA responded (TaxInterpretations translation): [A] "regional county municipality", which is an entity formed by letters patent issued by the Government of Quebec and which, following the adoption of the L and Use Planning and Development Act …, is expected to take care of the development of a territory, is a municipality for purposes of the Act. ...
Technical Interpretation - External summary

10 June 2016 External T.I. 2015-0590371E5 F - Résidence principale - stationnement -- summary under Paragraph 40(2)(b)

10 June 2016 External T.I. 2015-0590371E5 F- Résidence principale- stationnement-- summary under Paragraph 40(2)(b) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) designating condo parking space for a year does not exhaust exemption for the condo unit Where a parking space was acquired as part of the purchase of a residential condo unit, the parking space can thereafter form part of the condo unit (viewed as a “housing unit” for principal residence exemption purposes) provided that the parking space facilitates the use of the housing unit (which presumably would always be the case if it is actually used by the condo owner) and it is part of the common or private area for the same building and this is so even if the parking space as a matter of real property law is a separate from the condo unit. ...
Technical Interpretation - External summary

17 May 2016 External T.I. 2015-0603711E5 F - Personne assumant les frais d'entretien -- summary under Supporting Person

. Parent1 does not have to consider Parent2 when completing Form T778 as Parent2 is not a "supporting person" for purposes of the child care expenses deduction. ...

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