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Administrative Policy summary
Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024 -- summary under Gross Revenue
IV of the Regs. 2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s. 248(1)] also applies for purposes of the Regulations. ...
Administrative Policy summary
Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024 -- summary under Subsection 402(6)
When a corporation conducts all or part of its operations in partnership with one or more other persons, subsection 402(6) of the Regulations provides that for the purposes of subsection 402(3) … the corporation must include in its gross revenue for the tax year and in its salaries and wages paid in the tax year its proportionate share of the gross revenue of the partnership and the salaries and wages paid by the partnership. ...
Administrative Policy summary
Selected listed financial institutions (SLFI), October 16, 2015 -- summary under Subsection 301(1.1)
. … Quebec SLFI objection Effective January 1, 2013, the CRA administers the QST applicable to SLFIs. ...
Administrative Policy summary
S3-F3-C1 - Replacement Property -- summary under Subsection 44(6)
S3-F3-C1- Replacement Property-- summary under Subsection 44(6) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(6) Reallocation under s. 44(6) 1.18 … [U]nder subsection 44(6), a taxpayer may be permitted to reallocate the POD of a former business property composed of land and one or more buildings between the land component and the building component. ...
Administrative Policy summary
GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025 -- summary under Subsection 22(1)
. … Application of general rules 14. If these rules do not determine the place of supply of the transportation pass (for example, where the passenger transportation services covered by the passenger transportation pass may not always begin in the same participating province), the place of supply is determined under the general place of supply rules for intangible personal property. ...
Administrative Policy summary
IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998 -- summary under Paragraph 214(3)(a)
IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) No penalty if tax remitted by Feb 15/based only on net annual increase in balance 38....If there is no series of loans or other transactions and repayments (see ¶ 28 above), the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the taxation year of the lender, in order to determine if the exception under subsection 15(2.6) applies. ...
Administrative Policy summary
IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences" -- summary under Class 14
Where renewal or extension periods are considered part of the life of the property under the criteria set out in ¶ 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ...
Administrative Policy summary
8 July 2013 Interpretation Case No. 145134 -- summary under Section 181.1
. … [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...
Administrative Policy summary
Taxable Supplies - Special Cases [CRA website] -- summary under Subsection 153(1)
. … Tips and gratuities …A tip or gratuity that is freely given by a customer, for example, cash not recorded on a bill, is not subject to the GST/HST. ...
Administrative Policy summary
2 December 2014 CTF Roundtable, Q. 9 -- summary under Paragraph 95(6)(b)
However, … paragraph 95(6)(b) could still apply in other contexts such as… the manipulation of a taxpayer's participating percentage in a controlled foreign affiliate. ...