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News of Note post
Summary of Circular of H&R REIT and H&R Finance Trust under Other – Releveragings. ...
News of Note post
These (and the other full-text translations covering the last 3 ½ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. ...
News of Note post
Summaries of Angelo Discepola and Robert Nearing, "A Reply to the CRA's Classification of Florida and Delaware LLLPs and LLPs as Corporations," 2016 Conference Report (Canadian Tax Foundation), 24:1-39 under s. 96 and s. 248(1) – corporation. ...
News of Note post
20 February 2018- 11:54pm Five full-text translations of 2013 APFF Roundtable items and Technical Interpretations are available Email this Content The table below provides descriptors and links for two items from the October 2013 APFF Roundtable, as fully translated by us – as well as for three technical interpretations released in January 2014. ...
News of Note post
Tremblay case, Bédard J found that house-repair invoices, that did not give the house address or describe the precise nature of the work performed (and that were rendered in the name of entities that did not remit the GST), failed to satisfy the requirements of s. 3 of the Input Tax Credit Information (GST/HST) Regulations, so that the appellant’s related input tax credit claims were properly denied – and also found that “the appellant did not truly acquire the supplies for which it claimed ITCs.” ...
News of Note post
Summary of 29 May 2018 STEP Roundtable, Q.5 under s. 120.4(1) – excluded share. ...
News of Note post
CRA ruled that USco, following the New Services addition, is not carrying on business in Canada for GST/HST purposes – and also ruled that the supply of the New Services by Canco to USco is zero-rated pursuant to Sched. ...
News of Note post
However, it is necessary to read this rule in a purposive manner in order to make it work given that the operation of s. 104(13) dovetails with the s. 104(6) rule, which references an amount of income “that the trust claims” – whereas “it could be expected that such a trust will not file a Canadian tax return and will not be expressly claiming any deductions under the Act.” ...
News of Note post
Essentially, the SAM formula computes a normative amount of provincial HST based on the residence of the SLFI's ultimate stakeholders, and compares this with the actual provincial HST paid to its suppliers – and then requires that the difference be reported and claimed as refunds or remitted as tax, in interim and final returns. ...
News of Note post
– and, as a participant, it could then be designated as the JV operator. ...