Search - 报销 发票日期 消费日期不一致
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Technical Interpretation - External summary
22 April 2003 External T.I. 2002-0169565 F - ACTIF UTILISE DANS L'ENTREPRISE -- summary under Paragraph (c)
. … In the second situation, the instalments are paid in respect of income taxes generated by the corporation's active business and the payment of the instalments to the various governments is an obligation of the corporation and is required by the Act or by provincial law. ...
Technical Interpretation - External summary
25 April 2003 External T.I. 2002-0171075 F - AVANTAGE-POLICE D'ASSURANCE -- summary under Paragraph 6(1)(a)
. … [T]he coverage of the risk during the period covered by the premium will benefit the employee (or shareholder) if the employee's (or shareholder's) beneficiaries are the beneficiaries of the life insurance policy during that period. ...
Technical Interpretation - External summary
25 April 2003 External T.I. 2002-0171075 F - AVANTAGE-POLICE D'ASSURANCE -- summary under Subsection 15(1)
. … [T]he coverage of the risk during the period covered by the premium will benefit the employee (or shareholder) if the employee's (or shareholder's) beneficiaries are the beneficiaries of the life insurance policy during that period. ...
Technical Interpretation - Internal summary
1 May 2003 Internal T.I. 2002-0178347 F - BENEFICES FABRICATION -- summary under Cost of Manufacturing and Processing Labour
For purposes of computing the s. 125.1(1) credit, should "adjusted business income" include such expense reimbursements, and should such reimbursements reduce Canco’s "labour cost" and "cost of manufacturing and processing labour "? ...
Technical Interpretation - External summary
23 May 2003 External T.I. 2002-0172205 F - FIDUCIE DE BIEN-RE&S -- summary under Subparagraph 18(9)(a)(iii)
CCRA stated: [I]t seems to us that the arrangement between the employer, the trust and the insurer could resemble a health and welfare trust, provided that the conditions of … IT-85R2 are satisfied, including, among other things, that the employer does not have control over the use of trust funds. ...
Technical Interpretation - External summary
15 April 2003 External T.I. 2002-0139305 F - Immigration -- summary under Subparagraph 53(1)(e)(i)
X would be allocated his share of the capital gain – but that since the ACB of his partnership interest was increased to FMV under former s. 48(3) on his immigration and further increased by his capital contribution and his share of the capital gain, he would realize a capital loss on the partnership winding-up. ...
Technical Interpretation - Internal summary
26 May 2003 Internal T.I. 2003-0002297 F - Fonds commun de placement-Dépenses gén. -- summary under Subsection 104(6)
In those cases, the trust will be able to apply those expenses against its income other than taxable dividends, including against its net taxable capital gains … in order to allow for the maximum possible flow-through of the dividend tax credit to a beneficiary or beneficiaries, provided that this method does not contravene the legislative provisions relating to trusts or the trust agreement. ...
Technical Interpretation - Internal summary
26 May 2003 Internal T.I. 2003-0002297 F - Fonds commun de placement-Dépenses gén. -- summary under Paragraph 20(1)(bb)
In this regard, it is important to note that it is not necessary for such advice to result in an actual acquisition or disposition for the fees paid for such advice to be deductible (see document # E 9607657). ...
Technical Interpretation - Internal summary
14 May 2003 Internal T.I. 2003-0181477 F - DEDUCTIBILITE DES INTERETS -- summary under Subparagraph 20(1)(c)(i)
. … [A] taxpayer cannot use this method to meet the traceability/linkage test if tracing can be done. ...
Technical Interpretation - External summary
3 June 2003 External T.I. 2003-0012075 F - Safe Income and 104(13.1) Designation -- summary under Paragraph 55(2.1)(c)
In finding that such amount would not be included in determining the corporate beneficiary's safe income or safe income on hand, CCRA indicated “that ‘safe income’ in respect of a share of a corporation means the net income of the corporation, determined in accordance with the Act and adjusted by paragraph 55(5)(b), (c) or (d) … that is attributable to that particular share during the holding period” so that, as the amount distributed to the corporation would not be included in its income by virtue of the operation of s. 104(13.1), such amount could not be included in its safe income. ...