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News of Note post
., until May 31, 2025) from this prohibition in order to facilitate the OEO Dealers in paying a rebate of such amounts to their clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...
News of Note post
In 2025, the capital cost of the property will have been reduced (pursuant to s. 13(7.1)(e)) by the two federal tax credits claimed and (pursuant to s. 13(7)(f)) by the NS CITC “assistance” claimed, i.e., to $4,500.000. ... Summary of 21 October 2024 External T.I. 2024-1027501E5 under Reg. 1100(2)(A), s. 127(9) government assistance and s. 13(1). ...
News of Note post
1 January 2025- 11:34pm CRA confirms that active business income includes income from property that (having regard to Ensite) is held principally for the purpose of producing active business income Email this Content The definition “income of the corporation for the year from an active business” in s. 125(7) includes, in para. ... Summary of 3 December 2024 CTF Roundtable, Q.14 under s. 129(4) “income” or “loss”. ...
News of Note post
6 January 2025- 11:16pm We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in March of 2001. ... These are additions to our set of 3,053 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...
News of Note post
6 February 2025- 11:48pm CRA finds that s. 152(4)(b)(vii) does not apply to extend the period for adjusting the income computation of a trust that filed as a s. 94 trust Email this Content A s. 94(3) trust reported a capital gain from the disposition of the shares of a foreign affiliate in its 2020 T3 return. In finding that s. 152(4)(b)(vii) did not authorize CRA to reassess the trust within three years of the expiry of the normal reassessment period to adjust the proceeds of disposition, the Directorate indicated: The relevant scoping condition in s. 152(4)(b)(vii) that the assessment was “to give effect to the application of section 94”- meant “to cause section 94 to apply.” ...
News of Note post
3 March 2025- 11:30pm We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in December of 2000. ... These are additions to our set of 3,123 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...
News of Note post
25 May 2025- 11:43pm CRA accepts a pre-butterfly amalgamation to create business property and a post-butterfly amalgamation to minimize Pt. ... Summaries of 2021 Ruling 2019-0821121R3 under s. 55(1) distribution and s. 96. ...
News of Note post
2 June 2025- 11:02pm We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in August and July of 2000. ... These are additions to our set of 3,215 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...
News of Note post
16 June 2025- 11:39pm We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in July of 2000. ... These are additions to our set of 3,227 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...
News of Note post
28 July 2025- 11:35pm We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in May of 2000. ... Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees legal fees incurred in unsuccessful attempt to maintain child support were deductible 28 April 2000 External T.I. 2000-0020695 F- CREDIT-BAIL Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Construction Bérou not followed after 1990 taxpayers generally should follow the legal form of the agreement General Concepts- Substance CRA generally assumes that the form of the agreement reflects the relationship ...

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