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Administrative Policy summary

Income Tax Technical News, No. 9, 10 February 1997 -- summary under Subparagraph 53(1)(e)(i)

. In circumstances where there is a possibility of double taxation, we are prepared, in the context of a ruling request, to apply the law in a manner such that a taxpayer is not taxed twice on the same amount. ...
Administrative Policy summary

28 March 2013 Interpretation Case No. 141341 -- summary under Subsection 27(6)

Therefore, the amount of ITC to be recaptured would be limited to the large business participant's interest, or $2,666.64 ($8,000 [HST Provincial Component] X 33 1/3 %). ...
Administrative Policy summary

Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 265(2)

. 7.18 Self-certification forms have been developed by the CRA to assist financial institutions in establishing the status of account holders under Part XVIII and Part XIX.... ...
Administrative Policy summary

17 May 2012 Interpretation File 97556 -- summary under Financial Service

Since CanCo and [its parent] USCo are not Interac Association Members, the Processing Services are contracted to a third party, […], an Interac Member and Acquirer. ...
Administrative Policy summary

Income Tax Technical News, No. 7, 21 February 1996 (cancelled) -- summary under Shares

Profit- Shares retention of shares' capital property character on intercorporate rollover transactions The questioner referred to the Revenue Canada position- that, in situations where a corporate taxpayer has acquired, on a section 85 "rollover," property that was non-depreciable capital property of a controlling shareholder or a "sister" corporation, it was ordinarily prepared to accept that the nature of the transferred property would not have changed solely because the taxpayer resold the property soon after the rollover and asked whether this position was affected by the Mara Properties decision (95 D.T.C. 5168 [subsequently reversed at [1996] 2 S.C.R. 161]). ...
Administrative Policy summary

IC 05-1R1 "Electronic Record Keeping" June 2005 -- summary under Subsection 230(4.1)

. 25. Electronic image means the representation of a source document that can be used to generate an intelligible reproduction of that document, or the reproduction itself. ...
Administrative Policy summary

26 February 2015 CBA Roundtable, Q. 23 -- summary under Paragraph 296(1)(a)

CRA considered that these provisions do not interfere with its current practice of simply assigning a GST/HST registration number to someone who should have been registered, and then assessing the person under that number for unremitted net tax and noted that CRA could still assess that person under paragraph 296(1)(a) of the ETA for unremitted net tax in respect of reporting periods prior to that person’s effective registration date. ...
Administrative Policy summary

13 March 1997 Interpretation 11735-1, 11720-1 -- summary under Subsection 182(1)

. If the car is not damaged during the rental period, no additional payment is required even though the taxable supply of the rental of the car has still been made by the car rental company and consumed by the renter. ...
Administrative Policy summary

May 2016 Alberta CPA Roundtable, GST Q.6 -- summary under Subsection 240(3)

. Requests are usually denied if there is insufficient proof. Taxpayers can resubmit the request and the appropriate proof to backdate the registration. ...
Administrative Policy summary

7 December 2016 Ruling 158637 -- summary under Subsection 232(1)

. Alternatively, persons that paid an amount as GST/HST on supplies that are exempt or on which no tax is payable may file an application for a rebate of amounts paid in error [on] Form GST 189…. ...

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