Search - 哈尔滨到北京 公里数

CRA responded: Based on … the operator … not hav[ing] an interest in the real property on which the MURC is situated, the operator does not meet the conditions set out in paragraph (a) of the definition of “builder.” ...

The remaining 40% of the services are not improvements to capital property, and are to be expensed for income tax purposes. … Therefore, the GST deemed payable for the improvements to the apartment building is $300 (i.e., $500 × 60%). The ITC available on the improvement is calculated in accordance with subsection 169(1) and paragraph (b) of element B of the formula in that subsection, and is equal to $60 (i.e., $300 × 20%). ... However, if the repair services were partly (e.g., 20%) for consumption or use in commercial activities and partly (e.g., 80%) for consumption or use in non-commercial activities, an ITC of $40 (i.e., $200 × 20%) could be claimed in accordance with subsection 169(1) and paragraph (c) of element B of the formula in that subsection. ...

Excise and GST/HST News- No. 114, August 2023-- summary under Section 154 Summary Under Tax Topics- Excise Tax Act- Section 154 Vancouver’s additional 2.5% hotel tax will increase the overall rate to above the 12% specified rate, thereby causing GST to be applied to the 13.5% provincial tax From February 1, 2023, until January 31, 2030 (effective period), the Major Events Municipal and Regional District Tax (Major Events MRDT) of 2.5% will apply to supplies of short-term accommodation made in the City of Vancouver … in addition to the 8% provincial sales tax (PST) and the 3% Vancouver Municipal and Regional District Tax (MRDT) …. For purposes of section 154 … the specified tax rate in BC is 12%. … [D]uring the effective period, the combined tax rate of 13.5% (PST at 8% plus MRDT at 3% plus Major Events MRDT at 2.5%) on supplies of short-term accommodation in Vancouver exceeds BC’s specified tax rate of 12%. ...

In finding that the return of the merchandise was not governed by s. 232 and was at taxable sale (so that the Retailer was correct in charging GST/HST)), CRA stated: … Memorandum 12.2 … states that a reduction in consideration may occur under various circumstances, including “where goods are returned to the supplier for a full or partial refund of the consideration.”… However, according to the terms of the Purchase Agreement, title and ownership of the merchandise is transferred to [the Retailer] upon delivery of the merchandise to [the Retailer] at the delivery point specified in the applicable purchase order. ...

The amount of tax payable by the non-profit or ganization is equal to $80 (2% (10% Nova Scotia provincial rate – 8% Ontario provincial rate) × $10,000 (the value of the consideration for the supply) × 40% (the extent to which the non-profit organization acquired the property for use in Nova Scotia)). ...

CRA stated: The … Priority Distribution is … a payment to [the manager] for performing the day-to-day supervision, management and operation of the Nursing Home [and it] is supplying these services to the participants in the joint venture. … [The manager] is reimbursed by the joint venture for the wages and salaries it pays to its employees. [The manager] makes a supply to the joint venture of the services of these employees [and] … is supplying these services to its co-participant [the charity]. ...

. … You may also have to report relevant information on Schedule 130 of your partnership information return if you have IFE or IFR, and have a corporation or a trust as a member. If your partnership has a corporation or a trust as a member, under the rules you should complete the following steps: Provide each member with detailed calculations of the partnership’s IFE and IFR Provide each member with detailed calculations of the RAIFE and RAIFR of any CFA of the partnership Notify each member in writing of their allocated share for the year of: IFE in Canadian exploration expenses, Canadian development expenses, Canadian oil and gas expenses, and foreign resource expenses The income or loss that can reasonably be considered to come from activities funded by a borrowing or other financing that results in exempt interest and financing expenses Filing approach before Schedule 130 is ready Schedule 130 … Schedule 130 information is still required even though the form is not available. … Corporations and trusts … When you report your foreign accrual property income, you must adjust for RAIFE denied under subclause 95(2)(f.11)(ii)(D)(I) and include amounts in respect of a CFA’s partnership under subclause 95(2)(f.11)(ii)(D)(II). ... The calculations should include enough details so that a total amount for each paragraph of the relevant definition is shown (refer to subsection 18.2(1)) A calculation of the proportion in subsection 18.2(2) showing an amount for each variable of the formula A calculation of restricted interest and financing expenses for the year, broken down to show amounts restricted under: Paragraph 12(1)(l.2) Subsection 18.2(2), and Subclauses 95(2)(f.11)(ii)(D)(I) and 95(2)(f.11)(ii)(D)(II) If your corporation or trust is a member of a partnership, you must include the share of all relevant partnership amounts when you calculate the corporation or trust’s ATI, IFE, and IFR. … Partnerships When you submit your partnership information return for the fiscal year, you must include the details of how the partnership calculated its IFE and IFR (refer to subsection 18.2(1)). ...

. … The CRA believes firmly that all participants in offshore tax evasion and tax avoidance schemes must be identified and brought into full compliance with their tax obligations. ... …There is no preferred treatment of certain taxpayers who are non-compliant over others. … …Where appropriate, including with matters before the courts, and in consultation with the Department of Justice, the CRA seeks to resolve matters through a settlement offer that is based on facts and in accordance with the law. ... Over $7 billion of that amount – about two-thirds – involves international and large business aggressive tax planning, including high net worth individuals and multi-nationals. ...

. … The CRA…will generally exercise administrative tolerance if this issue is … reported by the registrant or discovered … on audit. ... Pursuant to subsection 296(2) … the Minister must take into account an ITC for a particular reporting period when assessing the net tax for that reporting period even though the time limit for claiming the ITC may have expired. ... Administrative tolerance will not be granted where the purchaser is not entitled to claim a full ITC or where the purchaser has already claimed the ITC in a GST/HST return … [nor] where the purchaser was previously assessed under similar circumstances. ...

As discussed in the Excise and GST/HST Rulings memorandum issued […] on [mm/dd/yyyy] (RITS […]), where a receiver (such as a single asset receiver) is responsible for only a part and not all of the person's businesses, properties, affairs or assets, the receiver may use a sub-account of the person's GST/HST registration account for GST/HST purposes. ...