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Technical Interpretation - External
29 September 2022 External T.I. 2022-0949081E5 - CMETC -Qualified Engineer or Geoscientist
. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...
Conference
15 June 2022 STEP Roundtable Q. 18, 2022-0924791C6 - McNeeley et al v. The Queen
Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 Question 18. ...
Technical Interpretation - External
26 January 2023 External T.I. 2021-0887661E5 - Small Business Deduction - Related
XXXXXXXXXX 2021-088766 Matthew Ross, CPA, CA January 26, 2023 Dear XXXXXXXXXX: Re: Small Business Deduction – Related Corporations We are writing in response to your email of April 3, 2021 in which you requested our views regarding certain aspects of the small business deduction (“SBD”) rules found in section 125 of the Income Tax Act (“the Act”). ...
Conference
17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6 - Remote Work Arrangements
17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements Unedited CRA Tags Section 253; Canada – U.S. ...
Ruling
2022 Ruling 2022-0949231R3 - Loss Consolidation Ruling
XXXXXXXXXX 2022-094923 XXXXXXXXXX, 2022 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Supplement to file 2020-087076 XXXXXXXXXX We are writing in response to your email of XXXXXXXXXX wherein you submitted a request to make certain changes to the proposed transactions as they were described in the Advance Income Tax Ruling dated XXXXXXXXXX (2020-087076) (referred to as the “Original Ruling”) on behalf of the above-referenced taxpayers. ...
Technical Interpretation - External
14 June 2023 External T.I. 2021-0910211E5 - Indian Act exemption and business income
Nerill Thomas-Wilkinson, CPA, CA Manager Non-Profit Organizations and Indigenous Issues Speciality Tax Division Income Tax Rulings Directorate FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 The Queen v Robertson et al 2012 FCA 94; 2010 TCC 552 Leave to Appeal to the SCC dismissed 2 Ballantyne v The Queen 2012 FCA 95; 2009 TCC 325; 2012-10-25 SCC Docket 34840 – Leave to Appeal Dismissed with Costs 3 Paragraph 86 Robertson ...
Technical Interpretation - External
26 May 2023 External T.I. 2023-0962521E5 - Employment Expenses of a Pilot
Where the conditions of paragraph 8(1)(h) and subsection 8(4) of the Act are met, subsection 8(10) of the Act further requires that Form T2200 – Declaration of conditions of Employment be completed by the employer. ...
Conference
20 June 2023 STEP Roundtable Q. 16, 2023-0961321C6 - Damages in Respect of Personal Injury or Death
Where the amount received by the child, was not awarded as damages for mental injuries suffered by the child, paragraphs 81(1)(g.1) and (g.2) of the Income Tax Act would not apply and the investment income earned would be taxable. 2) An annuity contract purchased by a taxpayer or a taxpayer's representative with proceeds of a lump sum award received for damages for personal injury or death will be an annuity contract for purposes of the Income Tax Act and will, except where the lump-sum award is organized as a structured settlement or in circumstances where paragraphs 81(1)(g.1) and (g.2) of the Income Tax Act apply, give rise to income in the taxpayer's hands. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 16. ...
Conference
20 June 2023 STEP Roundtable Q. 15, 2023-0963801C6 - Interpretation of clause 110.6(1.3)(a)(ii)(A)
The fact that Father is not the person that owns the property at the disposition time or in the 24-month period immediately preceding the disposition would not preclude him from meeting the farming-use condition in clause 110.6(1.3)(a)(ii)(A) of the Act. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 15. ...
Technical Interpretation - Internal
10 May 2023 Internal T.I. 2021-0918031I7 - Ontario CMT - corrected adjusted net loss balance
The Queen, 74 DTC 1029. […] [28] The respondent's concern is unnecessary. ...