Search - 报销 发票日期 消费日期不一致

Summary of 1 February 2023 External T.I. 2022-0945221E5 under s. 149.1(1) – qualified disbursement. ...

CRA indicated that, very generally, a beneficiary of a trust is a person, other than the protector, who has the right to compel the trustee to properly enforce the terms of the trust, regardless of whether that person’s right to the income or capital of the trust is immediate, future, contingent, absolute or conditional on the exercise of the discretion of any person – so that, accordingly, a beneficiary in the ordinary sense would include a beneficiary whose interest is contingent. ...

In this regard, Headquarters observed that inter alia Clibetre and Orlando indicated that “where requested changes to elements of the taxpayer’s return of income are denied, and there is no change to the tax payable previously assessed … there has been no ‘reassessment’ of tax by the Minister,” and such denial is instead “simply a notification that a reassessment has not been done” (“even if the notification is titled a ‘Notice of Reassessment’.”) ...

Summary of 13 March 2023 External T.I. 2023-0961401E5 under s. 122.92(1) – qualifying renovation. ...

Summary of 24 January 2023 External T.I. 2018-0753471E5 F under s. 122.6 – adjusted income. ...

Summary of 2 November 2023 APFF Roundtable, Q.11 under s. 248(1) – disposition. ...

Regarding the situation where the parties had agreed to make the election without knowing that they were required to send in the election letter, CRA indicated that, given that s. 56.4(7)(g) was one of the provisions prescribed in Reg. 600, application could be made to extend the prescribed time for filing the election – and that this discretionary power would be exercised in light of its guidelines in IC 07-1. ...

Summary of 28 September 2023 CLHIA Roundtable Q. 1, 2023-0971701C6 under s. 148(9) – disposition. ...

Summaries of 2023 Ruling 2022-0950461R3 under s. 248(1) – disposition and s. 96. ...

The Rulings Directorate emphasized that these capital gains had not been disclosed on applying for the clearance certificate, and concluded that “it is reasonable to consider that … the issuance of the clearance certificate by the CRA does not relieve the Legal Representatives of their personal liability pursuant to subsection 159(3).” ...