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Technical Interpretation - Internal summary

23 May 2012 Internal T.I. 2011-0418071I7 F - Remise de dettes, PAC -- summary under Paragraph 80(3)(a)

In other words, the settlement of a commercial debt that results in the application of section 80 automatically and immediately reduces the NCL balance for a taxation year because of the D.2 element of the NCL definition in subsection 111(8). ­­­­­­­­­­­­­­­­­­­­­­­ ...
Technical Interpretation - Internal summary

14 May 2012 Internal T.I. 2010-0367831I7 F - Régime de pension étranger. France -- summary under Subsection 5(1)

. Given that the employer acted on behalf of the employee by paying an invoice that otherwise would be borne by the employee, we are of the view that the amounts were constructively received by the employee. ...
Technical Interpretation - External summary

23 January 2012 External T.I. 2011-0424671E5 F - Avantage imposable - Stationnement -- summary under Paragraph 6(1)(a)

CRA then stated: As an indication, where an employee is required to use the employee’s automobile, or a car provided by the employer, three or more days a week to perform the duties of employment, and uses the parking space for that purpose, we generally consider that the parking space is used regularly for reasons related to the employee’s employment. ...
Technical Interpretation - Internal summary

24 April 2012 Internal T.I. 2012-0440711I7 F - Indemnité de repas; remboursement pour déplacement -- summary under Paragraph 6(1)(b)

As a result, the total amount of the allowances, as well as meal vouchers, should be included on the T4 slip in box 14 …. ...
Technical Interpretation - External summary

15 August 2012 External T.I. 2012-0444461E5 F - Pompiers volontaires -- summary under Subsection 81(4)

. [A]n individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06. ...
Technical Interpretation - Internal summary

1 March 2012 Internal T.I. 2012-0437901I7 F - Timing of the adjustments pursuant to 111(5) -- summary under Paragraph 111(5)(a)

1 March 2012 Internal T.I. 2012-0437901I7 F- Timing of the adjustments pursuant to 111(5)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) acquisition of control of target does not reduce its NCLs at that time streaming rules apply prospectively A corporation acquired all of the shares of a target corporation, resulting in an acquisition of control, and a day later, they amalgamated to form "Amalco". ...
Technical Interpretation - Internal summary

1 December 2015 Internal T.I. 2015-0588381I7 F - Classification of US-LLCs -- summary under Section 96

. [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...
Technical Interpretation - External summary

15 December 1998 External T.I. 9819355 - FOREIGN AFFILIATES - FOREIGN ACCRUAL TAX -- summary under Foreign Accrual Tax

. [T]he U.S. tax paid by Usco on its share of the portion of the gain computed pursuant to the Code from the disposition of the Consideration Property by the Partnership that could reasonably be regarded as the gain and/or recaptured depreciation determined pursuant to the Code that was deferred on the disposition of the Rental Property by the Partnership would qualify as FAT. ...
Technical Interpretation - External summary

10 June 2016 External T.I. 2015-0587131E5 F - Remboursement de frais de repas -- summary under Paragraph 6(1)(a)

. [W]here an employee incurs meals expenses for travel outside the municipality or metropolitan area [of the employer's establishment] and the employee is reimbursed by the employer, this amount is not included in the calculation of employment income because this travel mainly benefits the employer. ...
Technical Interpretation - Internal summary

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment -- summary under Subsection 5(1)

. Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...

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