Search - 报销 发票日期 消费日期不一致

After noting a current GAAR review by Aggressive Tax Planning, the Directorate stated that LeCavalier " supports the application of GAAR… where the debt parking rules … were considered to have been misused or abused. ...

After noting that “ Redclay [indicated that] ‘ was payable’ requires any GST/HST or PST actually paid pursuant to a vehicle purchase or lease contract to be included in the definition of cost for the purposes of subsection 6(2),” CRA indicated that under ETA s. 153(4)(c) “the GST/HST paid is not reduced because of an exemption [as referred to in s. 6(7)] but is reduced because of a calculation of the GST/HST base,” and the same analysis appeared to apply in the PST provinces. ...

X's capital cost ($200,000) and the amount by which that cost exceeded the proceeds of disposition ($50,000) would be deemed to be CCA deducted in preceding taxation years, whereas “the capital cost to the corporation of the building for the purposes of all other provisions of the Act would, in accordance with our position in paragraph 10(a) of … IT-217R … be considered to be Mr. ...

. … [W]here the transaction is not commercially reasonable, the borrowed money does not meet the test in paragraph 20(1)(c) of being used for the purpose of earning income. [T]he fact that Profitco's income is "foreign accrual property income" … will not, in and of itself, change the Agency's position. ...

After noting that “the weekly blood tests in this case would likely be considered an activity that would be included in the time spent administering therapy” since the “weekly blood tests were required to ensure that the proper Phe level was being maintained,” the Directorate stated: It is … a question of fact whether the determination of a specific activity, for example a weekly blood test, can be included in the time spent administering therapy as described in paragraph 118.1(1)(a.1) of the Act. … What would be considered essential to one person’s impairment may not be considered essential to another. ...

Accordingly … “three months” generally means the aggregation of the number of days in three months. ... Thus, preparation time generally would not be counted towards the three month testing period. … Regarding standby time, i.e., “generally a temporary pause from operation that could be caused, for example, by severe weather, or shortage of labour,” it stated: Such temporary interruption should not change the status that the installation or drilling rig or ship in question is being utilized in the business. ...

14 September 1996 External T.I. 9629825- PHSP CVRGE FOR SAME SEX LIFE PRTNER OF AN EMPLOYEE SECTION 6(1)(a)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Following the HRC decision in Moore & Akerstrom, RC has determined that a plan which provides coverage for same sex couples can meet the definition of a "private health services plan". ...

., exclusive possession of the property was not given), CRA cited Will-Kare for the proposition that " the concepts of a sale or a lease have settled legal definitions. ...

After finding that there was no exemption for the diplomat in Art. 34 of the Vienna Convention on Diplomatic Relations from the s. 162(7) penalty as the property " was not held on behalf of the sending State as part of the mission," nor was there any exemption for the child, CRA stated that "you may wish to consider exercising discretion in assessing the penalty given that….there was a loss on the property. ...

After finding that there was no exemption for the diplomat in Art. 34 of the Vienna Convention on Diplomatic Relations from the s. 162(7) penalty as the property " was not held on behalf of the sending State as part of the mission," nor was there any exemption for the child, CRA stated that "you may wish to consider exercising discretion in assessing the penalty given that….there was a loss on the property. ...