Search - 报销 发票日期 消费日期不一致
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Technical Interpretation - External summary
23 February 2005 External T.I. 2004-0093921E5 F - Déménagement d'un employé-Paiement de frais -- summary under Paragraph 6(1)(a)
. … While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...
Technical Interpretation - Internal summary
28 February 2005 Internal T.I. 2004-0103991I7 F - Remboursement de frais de scolarité -- summary under Paragraph 6(1)(a)
Furthermore, the Taxpayer was to return to the Employer's employ for a period at least as long as the number of years she had pursued her doctoral studies and on the date of her submission … she was still employed by the Employer. ...
Technical Interpretation - External summary
22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.5(2)
. … [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...
Technical Interpretation - External summary
17 April 2001 External T.I. 2000-0056455 F - AVANTAGE IMPOSABLE-EMPLOYE -- summary under Paragraph 6(1)(a)
For example [there would be such] benefit … if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...
Technical Interpretation - Internal summary
10 May 2001 Internal T.I. 2001-0066047 F - CRITERES RÉSIDENCES D'ACCUEIL -- summary under Paragraph 81(1)(h)
Regarding the meaning of "or the taxpayer’s principal place of residence is maintained for use as the residence of that other individual,” the Directorate stated: The phrase … refers to specific situations, such as where a taxpayer receives amounts because the taxpayer’s principal place of residence is available to host beneficiaries at any time for various periods. ...
Technical Interpretation - External summary
28 June 2001 External T.I. 2001-0069865 F - CRÉDIT-BAIL -- summary under Subsection 248(3)
. … [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...
Technical Interpretation - External summary
22 June 2001 External T.I. 2001-0075275 F - Dommages-intérêts -- summary under Paragraph 12(1)(c)
. … Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...
Technical Interpretation - Internal summary
19 June 2001 Internal T.I. 2000-0062787 F - FRAIS JURIDIQUES-GARANTIE -- summary under Legal and other Professional Fees
. … The limited partners did not really seem to have a choice as to whether or not they would agree to guarantee the LP loan. ...
Technical Interpretation - Internal summary
24 May 2001 Internal T.I. 2000-0047827 F - PENSION ALIMENTAIRE-CLAUSE RETROACTIVE -- summary under Paragraph (a)
In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...
Technical Interpretation - Internal summary
26 April 2001 Internal T.I. 2000-0046367 F - DEBENTURES CONVERTIBLES -- summary under Paragraph 20(1)(f)
. … [T]he amount paid is the stated capital in respect of the Class A shares which reflects the price agreed between the corporation and the debenture holders. ...