Search - 报销 发票日期 消费日期不一致
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Commentary
Nature of Income - Commentary
Amounts received as trustee or agent Where amounts are received by a taxpayer in trust for a third party or as agent, they will be excluded from its income (B & B, St Catharines Flying Training School, Gault, see also Bouck). ...
Commentary
ILP definition
The definition of financial institution” in that FATF definition is focussed on situations where there is a vehicle for holding relatively liquid investments, including liquid trading assets such as derivatives, and is not directed at situations where the vehicle controls and has ultimate management responsibility for operating businesses or a real estate portfolio – even where they are held through subsidiary entities such as LPs, unit trusts or, perhaps, corporations. ... Depending on the circumstances, it may be difficult to determine whether the relative value of the partnership interest of B (which is a pension fund subsidiary) is 50% or more of all the partnership interests – and this relative valuation may change from month to month. ... However, the potentially quite significant penalties for not filing annual returns (on form GST111 or RC7291) under s. 284.1 do not apply to a distributed investment plan (as per s. 273.2(2) and s. 6 of the Financial Services and Financial Institutions (GST/HST) Regulations); and penalties computed under s. 280.1 for failure to file the monthly (e.g., RC7262 or GST62) and annual returns under s. 238(2.1) are calculated as a function of the unremitted tax owing under a monthly and annual application of the applicable SAM formula (i.e., no SAM tax – no s. 280.1 penalty). ...
Commentary
Subsection 212.3(15) - Commentary
Draft s. 212.3(15)(a)(i) departs from these (multiple control) rules by providing that a CRIC that is controlled by more than one non-resident corporation is deemed not to be controlled by any such corporation that controls another non-resident corporation that controls the CRIC – unless the application of this deeming rule would result in the CRIC not being controlled by any non-resident corporation. ...
Commentary
Subsection 5(1) - Commentary
S. 5(1) also includes income from an " office," which is defined in s. 248(1). ...
Commentary
Paragraph 88(4)(b) - Commentary
The question arises as to whether such parent (Amalco) can satisfy the requirement that the shares of Pubco were received by the Target shareholders in consideration for their shares of Amalco – when in fact, the Pubco share were instead issued in consideration for the acquisition of the shares of a predecessor of Amalco, namely, Target. ...
Commentary
Subsection 212.3(7) - Commentary
However, the Explanatory Notes of the Department of Finance state: Where, for example, a parent first contributes cash to the CRIC in exchange for shares of the CRIC with PUC equal to the amount of the cash and the CRIC subsequently uses that cash to make an investment in a subject corporation, it is intended that only the deemed dividend rule apply – the PUC creation would not be considered to relate to the investment, as it is one step removed. ...