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News of Note post
Pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3)
3 December 2017- 7:30pm Pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3) Email this Content Para. ... Summary of 11 October 2017 Internal T.I. 2017-0719181I7 F under s. 66.1(6) – CEE – para. ...
Archived CRA website
ARCHIVED – Partnerships – Deferral of Corporate Tax
ARCHIVED – Partnerships – Deferral of Corporate Tax Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... Example: Taxation year end = TYE Fiscal period end = FPE Fig. 1 In this example, the stub period begins on February 1, 2011 (the first day of the partnership's fiscal period) and ends on December 31, 2011 (the last day of the corporation's taxation year). ... Using the formulaic approach, the stub period accrual income in a taxation year of a corporation will be determined as follows: A × B/C Where: A is the corporation's share of income, if any, from the partnership (other than dividends) for the partnership's fiscal periods that end in the taxation year; B is the number of days in the stub period; and C is the number of days in the partnership's fiscal periods that end in the taxation year. 10. ...
Current CRA website
Appendix A – Characterizing the supply being made – Image
Appendix A – Characterizing the supply being made – Image From: Canada Revenue Agency Previous page Page details Date modified: 2009-01-15 ...
News of Note post
7 March 2018- 1:11am Iggillis – Federal Court of Appeal indicates that privilege is not lost when a tax opinion is shared with a party with a “sufficient common interest in the same transactions” Email this Content Solicitor-client privilege over a tax-planning memo prepared for the purchaser in a tax-structured purchase transaction by a tax lawyer was not lost when the tax lawyer provided the memo in draft form to the vendors' tax lawyer, whose comments resulted in memo revisions. ... Webb JA stated: [W]hen dealing with complex statutes such as the Income Tax Act, sharing of opinions may well lead to efficiencies in completing the transactions and the clients may well be better served as the application of the Income Tax Act will be of interest to all of the parties to the series of transactions. … [The appellants] had sufficient common interest in the transactions to warrant a finding that … the … memo is protected from disclosure by solicitor-client privilege. ... The Queen, 2018 FCA 51 under s. 232(1) – solicitor-client privilege. ...
News of Note post
20 December 2019- 12:42am Loyer Succession – Federal Court allows review application for failure of CRA to consider a penalty-waiver agreement of the ARQ for the same unreported income Email this Content The estate of a suspected drug dealer, who had been murdered, was assessed by the ARQ for income that he had not reported. CRA followed suit with assessments made on the same basis – but CRA did not follow the ARQ’s lead when the latter agreed with the estate to waive all gross negligence penalties- and did not even mention the Agreement to this effect between the estate and the ARQ in its second level review of the estate’s request under s. 220(3.1) for relief. ... The failure to do neither … had the effect… of “depriving the process of justification, transparency and intelligibility,” to adopt … Telfer …. ...
Current CRA website
Infographic – Benefit and credit payments – English
Infographic – Benefit and credit payments – English The official versions of the CRA factsheet and infographics on benefits and credits are the English and French versions. ...
Current CRA website
SR&ED T661 Claim Form – 2013 Revision – Claim preparer information
SR&ED T661 Claim Form – 2013 Revision – Claim preparer information Date: October 31, 2013 The March 2013 Federal Budget proposed changes to the Scientific Research and Experimental Development (SR&ED) Program. ... Therefore, the 2013 version of the Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, contains new Part 9 – Claim preparer information. ... For more information please refer to the 2013 version of the T4088, Scientific Research and Experimental Development (SR&ED) Expenditures Claim – Guide to Form T661. ...
Archived CRA website
ARCHIVED – My Business Account – Responses to Enquiries
ARCHIVED – My Business Account – Responses to Enquiries Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ...
Technical Interpretation - Internal summary
8 June 2018 Internal T.I. 2018-0744881I7 - Regulation 403 – allocation of income -- summary under Subsection 403(3)
8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income-- summary under Subsection 403(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 403- Subsection 403(3) PE for 403(3) purposes includes any PE of any partnership of which insurer is member An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no insurance business and have permanent establishments in other provinces, but are not involved in an insurance business. ... Consequently … the taxpayer will have a PE in any province where the partnerships have a PE. … [B]ased on the fact that the taxpayer derives income (premiums) from reinsuring property situated in a province where the taxpayer has a PE due to being a member of a partnership, subsection 403(1) of the Regulations will allocate the taxpayer’s taxable income on a proportional basis to that province. … In view of the taxpayer having a PE in the province(s) where the partnerships have a PE, subsection 403(3) does not apply to the taxpayer with respect to those provinces. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – December 14, 2018
Challenges arise at the audit and reassessment stage relating to low levels of cooperation from taxpayers / advisors who draw out the audit process and proceed to litigation. ... Peace officer status for investigators (non armed); international liaison officers embedded in foreign jurisdictions CRA definition of ‘criminal tax evasion’; second track for criminal tax evasion with lower consequences and lower burden of proof Privilege – court decisions, academic views Cryptocurrency exchangers – demo of other tax administrations’ tools to detect Performance measurement challenges – demonstrating value of increased data and BI Incentives to encourage taxpayer cooperation 7. ... Next steps / forward agenda A telephone discussion will be organized for January to review and refine the list of priorities identified during today’s meeting. ...