Search - 哈尔滨到北京 公里数
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Decision summary
Fournier v. Agence du revenu du Québec, 2018 QCCQ 786 -- summary under Rectification & Rescission
Agence du revenu du Québec, 2018 QCCQ 786-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission taxpayer could reverse an assessment for a taxable benefit by subsequently engaging in self-help rectification On August 15, 2007, Mr. ...
Decision summary
Kraft Heinz Canada ULC v. Canada (Attorney General), 2022 BCSC 796 -- summary under Rectification & Rescission
Canada (Attorney General), 2022 BCSC 796-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission declaration made by the parties that their contribution was annulled under Dutch law appeared to have retroactive effect The petitioners were a Dutch cooperative (“Heinz Co-op”) and a B.C. unlimited liability company (“KH Canada”) which was the sole member of Heinz Co-op and the subsidiary of a U.S.- resident corporation. ...
TCC (summary)
Safety Plus Inc. v. R., 99 DTC 537, [1999] 3 CTC 2123 (TCC) -- summary under Scientific Research & Experimental Development
., 99 DTC 537, [1999] 3 CTC 2123 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Two projects for the development of a system for recycling sludge or dealing more economically with the disposition of waste chemicals did not evidence a type of uncertainty that could not be removed by standard engineering practice and routine development and, accordingly, did not qualify. ...
TCC (summary)
Knowledge Systems Inc. v. The Queen, 2000 DTC 2353 (TCC) -- summary under Scientific Research & Experimental Development
The Queen, 2000 DTC 2353 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development McArthur TCJ found (at p. 2360): "What the Appellant did was take existing technology computer hardware and PacRat software, and record personal messages that cannot be understood or tested by anyone else but [its principal]. ...
TCC (summary)
Telecomsyst Services Inc. v. The Queen, 97 DTC 684, [1997] 1 CTC 2256 (TCC) -- summary under Scientific Research & Experimental Development
The Queen, 97 DTC 684, [1997] 1 CTC 2256 (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 was found not to be engaged in SR&ED given that the only tests conducted by it in the year in question was testing of devices already on the market that had been designed from technologies developed in the United States. ...
TCC (summary)
Advanced Agricultural Testing Inc. v. The Queen, 2009 DTC 687, 2009 TCC 190 -- summary under Scientific Research & Experimental Development
The Queen, 2009 DTC 687, 2009 TCC 190-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer in carrying out work largely under the supervision of a researcher who was not its employee or representative, and in testing the effectiveness of products that had already been commercially developed, did not qualify for deduction as SR&ED. ...
TCC (summary)
Tacto Neuro Sensory Devices Inc./Appareils Neurosensoriels Tacto Inc. v. The Queen, 2005 DTC 457, 2004 TCC 341 -- summary under Scientific Research & Experimental Development
The Queen, 2005 DTC 457, 2004 TCC 341-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Work carried out by the taxpayers to improve the performance of a tactometer represented "routine techniques and standard procedures generally accessible to competent professionals in the field" (p. 461), and did not qualify as SR&ED. ...
TCC (summary)
ETA Performance Systems Corp. v. MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC) -- summary under Scientific Research & Experimental Development
MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development A supposed research project which folded after the initial phases of work and therefore consisted only of routine data collection and research in the educational area did not qualify as scientific research described in Regulation 2900. ...
TCC (summary)
Revelations Research Ltd. v. MNR, 92 DTC 1036, [1992] 1 CTC 2136 (TCC) -- summary under Scientific Research & Experimental Development
MNR, 92 DTC 1036, [1992] 1 CTC 2136 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Christie A.C.J. accepted the evidence of the Crown's scientific expert that the proposed research program of the taxpayer was not carried out in any systematic, scientific manner and that the principals involved had no work experience in the central areas of the project. ...
Technical Interpretation - Internal summary
13 June 2012 Internal T.I. 2012-0435351I7 F - SEPE - chèques en circulation -- summary under Payment & Receipt
13 June 2012 Internal T.I. 2012-0435351I7 F- SEPE- chèques en circulation-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, payment by cheque does not occur until debiting of bank account Are the cash assets of Opco reduced by the amount of issued and outstanding cheques that have not yet been cashed? CRA responded: Under the civil law in force in Quebec, the delivery of an outstanding cheque does not constitute payment … [and] the date of payment of a debt settled by cheque is considered to be the date on which the cheque is honoured or paid by the bank …. [Here] the cheques in circulation and not yet cashed do not constitute payments of the amounts due to Opco's suppliers and … consequently, there can be no reduction in the amount of the cash of Opco as long as the bank does not honour or pay such cheques. ...