Search - 报销 发票日期 消费日期不一致
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News of Note post
., 2017 FCA 243 under s. 220(2.1) and Statutory Construction – Specific v. general provision. ...
News of Note post
27 December 2017- 1:01am CRA considers that a self-insured health care spending account (“HCSA”) for a sole employee-shareholder likely will not qualify as a private health services plan Email this Content CRA considers that: In a situation where a corporation provides a self-insured HCSA for its only employee who is also its sole shareholder … it is likely that the sole employee-shareholder would be reimbursed for the full amount allocated to him or her annually. ...
News of Note post
Summaries of 26 September 2017 Ruling 126881 under ETA s. 259(1) – facility supply. ...
News of Note post
Under the Gabco test, a salary is unreasonable if “no reasonable businessman would have contracted to pay such an amount having only [his] business considerations … in mind. ...
News of Note post
22 February 2018- 1:46am CRA confirms that a distributor is not required to produce goods in respect of which it pays a copyright royalty Email this Content S. 212(1)(d)(vi) exempts a copyright royalty “in respect of the production or reproduction of any … artistic work.” ...
News of Note post
26 February 2018- 11:24pm CRA indicates that the deemed U.S. income inclusion from an IRA on renouncing U.S. citizenship or relinquishing a green card also is recognized for ITA purposes Email this Content Where a U.S. long-term resident relinquishes her green card (or a U.S. citizen renounced citizenship) after having become a Canadian resident, there would be a deemed taxable distribution to her of the amount in her IRA for Code purposes – which by virtue of ss. 56(1)(a)(i)(C.1) and 56(12) would be deemed to be included in her income at that time for ITA purposes as well. ...
News of Note post
Summaries of 7 February 2018 External T.I. 2016-0637221E5 under s. 66.2(5) – Canadian development expense and s. 85(1)(a). ...
News of Note post
The proposed transactions entailed the s. 85(1) transfer by him to a Newco of his Opco shares for notes in an amount close to the transferred shares’ hard ACB and preferred shares as to the balance – followed by an amalgamation (or wind-up) of the Opcos over a year later and gradual repayment of the notes on a redacted timetable. ...
News of Note post
CRA stated: Although the [children’s programs] are enriched by recreational and athletic activities … the primary purpose of the programs is to provide care and supervision to children 14 years of age and under. ...
News of Note post
Summaries of 13 December 2017 Interpretation 187306 under ETA s. 225.1(2) – B and s. 169(1). ...