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Administrative Policy summary

21 February 2000 T.I. 1999-0010295 -- summary under Subsection 20(12)

. To the extent that the U.S. taxes are not used for claiming a foreign tax credit, they may be deducted under subsection 20(12)…. ...
Administrative Policy summary

8 June 2016 CTF Technical Seminar: Update on s. 55(2) -- summary under Paragraph 55(2.1)(b)

The changes to s. 55(2) were meant to address the type of planning raised by D & D Livestock, where ACB is created (without being caught by existing s. 55(2) because there was no gain on the shares in question). ...
Administrative Policy summary

5 February 2016 Interpretation 153241 -- summary under Section 5

. Accordingly, the supply of an IME by a medical practitioner is exempt under section 5…. ...
Administrative Policy summary

25 February 2016 CBA Roundtable, Q. 7 -- summary under Paragraph (c)

CRA indicated that it can accept such an arrangement as being valid notwithstanding that all of the source deductions are handled on the payroll account of only one of the dentists, who does the remittances, and source deduction and T4 reporting, as agent for the other dentists as well as on her own behalf and also pays the staff remuneration as agent and is reimbursed on a pro rata basis by the other dentists. ...
Administrative Policy summary

19 January 2017 Ruling 172004 -- summary under Supply

After ruling that the contributions to the Trust Fund made by the employers through the Organization pursuant to the collective agreements were not consideration for a supply, CRA stated: [T]he payment of amounts is an industry development fee set by [the Organization] which is authorized [under the Legislation] to do so […]. ...
Administrative Policy summary

MLTT Rates and Calculation -- summary under Subsection 2(1)

For more information regarding amendments to the MLTT rate and rebate structure, please see the February 15, 2017 Council agenda item EX22.2: Capital and Operating Budgets (item # 311), and Bill 123 to amend to the City's Municipal Code Chapter 760, Taxation, Municipal Land Transfer Tax. ...
Administrative Policy summary

28 April 2017 Interpretation 154249 -- summary under Recipient

. Consequently, the Assignee is not considered the recipient of the supply of software licences and is not entitled to claim an ITC for the GST/HST paid for them to the Vendor. ...
Administrative Policy summary

23 March 2017 CBA Commodity Taxes Roundtable, Q.17 -- summary under Subsection 261(1)

(b) Any administrative position taken would be at audit’s discretion at the time of audit and based on the facts of the case at hand. ...
Administrative Policy summary

15 September 2017 Interpretation 169313 -- summary under Subsection 199(3)

. Example An individual registrant that had a passenger vehicle that was used for personal use, will now be used 100% as a taxi. ...
Administrative Policy summary

11 July 2018 Ruling 187784 -- summary under Municipal Transit Service

CRA stated: [T]he Cooperative was a transit authority as it was a non-profit organization that received funding from the Province and the Municipality to support the supply of public passenger transportation services, and all or substantially all of the its supplies were supplies of public passenger transportation services provided within the Municipality and its environs. ...

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