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Administrative Policy summary

27 February 2020 Report of the Quebec Ombudsman entitled "“So that taxpayers’ rights are upheld in payment arrangement proposals with Revenu Québec” -- summary under Subsection 169(3)

The report found that it was abusive and improper for the ARQ to reassess without an adequate evidentiary foundation capable of surviving judicial scrutiny and that, in such instances, the reassessment should be dropped. ...
Administrative Policy summary

Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021 -- summary under Subsection 153(1.1)

. If a Canadian resident employee of a non-resident entity is forced to perform their employment duties in Canada on an exceptional and temporary basis as a result of the Travel Restrictions and that employee has been issued a letter of authority applicable to the tax year including that period, the letter of authority will continue to apply and the withholding obligations of the non-resident entity will not change in Canada as long as there are no changes to the withholding obligations of the non-resident entity in the other jurisdiction. ...
Administrative Policy summary

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Paragraph (a)

However, there are some exceptions and certain corporations that are exempt from tax can still be eligible …. ...
Administrative Policy summary

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Subparagraph (d)(ii)

Eligible employers who on March 15, 2020 employed one or more individuals and allowed a third party with a business number to make payroll remittances on their behalf, through the third party’s account, will need to register for their own payroll program account. ...
Administrative Policy summary

2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4 -- summary under Paragraph 153(1)(a)

2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no dispensation from source deductions for non-resident employers whose employees work from Canada due to COVID travel restrictions If an individual is not ordinarily resident in Canada, but is in Canada due to Travel Restrictions or otherwise due to public safety concerns relating to COVID-19, and works remotely (for their non-resident employer) from Canada, would the employer, if it has no Canadian ties, now be subject to withholding obligations in Canada including in the situation where it did not consent to this Canadian nexus? ...
Administrative Policy summary

2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.15 -- summary under Subparagraph 125.7(4)(e)(ii)

The ancillary documents indicate this targets a cash-basis taxpayer; what about one who uses accrual accounting, but deviates from GAAP in some other respect for example, a taxpayer which does not net discounts against revenues, instead reporting them as an expense, or nets bad debts against revenues. ...
Administrative Policy summary

Excise and GST/HST News - No. 108 September 2020 -- summary under Paragraph 2(e)

Excise and GST/HST News- No. 108 September 2020-- summary under Paragraph 2(e) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part I- Section 2- Paragraph 2(e) CRA’s existing policy re drugs with mixed substances is consistent with Patterson Dental [Patterson Dental held] that the supply of epinephrine in combination with an analgesic in the appellant’s solutions was not a single supply containing a taxable element and a zero-rated element, and was therefore not zero-rated …. ...
Administrative Policy summary

IT-350R ARCHIVED - Investigation of Site 6 June 1977 -- summary under Paragraph 20(1)(dd)

. 3. The purpose of the investigation of a site may be to determine whether the land is physically suited for the planned building or other structure or whether such a building or structure would be economically viable on that site, or it may be a combination of those two objectives. ...
Administrative Policy summary

Guidance: How the Canada emergency wage subsidy affects SR&ED claims 19 February 2021 CRA Webpage -- summary under Subsection 127(19)

Under the proxy method, its qualified expenditures include only Sarah’s salary for the period, but are grossed-up by the 55% prescribed proxy amount, and that total is reduced by all and 30%, respectively, of the CEWS received by the corporation in relation to their respective salaries for that period. ­­­­­­­­­­­­­­­­­­­­ ...
Administrative Policy summary

GST24 Election and Revocation of the Election to Tax Professional Memberships -- summary under Section 18

. Election on class-by-class basis If you supply different classes of memberships that do not have the same fees, rights and privileges as other classes, you can make this election on a class-by-class basis. ...

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