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Administrative Policy summary

28 May 2025 IFA Roundtable, Q.4 -- summary under Subsection 231.1(1)

Taxpayers are expected to have full access to the information pertaining to their obligations or entitlements under the ITA and to the extent these obligations are not met, CRA will exercise the powers under the ITA to enforce compliance with tax laws and maintain the integrity of the tax system. ...
Administrative Policy summary

25 February 2016 CBA Roundtable, Q. 4 -- summary under Subsection 317(3)

. 4(b) [Provincial exemptions] With the exception of Quebec, the CRA does not necessarily abide by the provincial exemptions when determining the rate to issue administrative garnishment action. ... Some examples…include situations where there were other sources of income and only one income source was to be subjected to garnishment action, assets that could be readily available to the debtor to generate funds to satisfy the tax debt in full or a substantial portion and the debtor was not cooperating, or situations where the provincial exemption amount would be insufficient to address the amount of arrears. [T]he CRA felt it was better to treat all debtors, in a similar circumstance, the same to the extent possible. ...
Administrative Policy summary

Non-Profit Organization Risk Identification Project Report 17 February 2014 -- summary under Paragraph 149(1)(l)

. A significant number of NPOs violate the incidental profit test or have large equity The results from the review of the randomly-selected organizations suggest that a significant portion of incorporated organizations would fail to meet at least one of the requirements set out in paragraph 149(1)(l)…. ...
Administrative Policy summary

IT-223 (Cancelled) "Overhead Expense Insurance vs. Income Insurance" 26 May 1975 -- summary under Income-Producing Purpose

. 3. Where the insurance policy provides a taxpayer carrying on business or practising a profession with a benefit for loss of income earning capacity such as income disability insurance, the premium on such a policy is a personal and living expense which is non-deductible and the benefit received by the taxpayer is not considered to be income subject to tax in his hands. 4. ...
Administrative Policy summary

6 June 2014 Interpretation 150533 -- summary under Subsection 162(2)

. Since B Co already owns the logs, the amounts paid by B Co are not consideration for a supply of logs by A Co but would appear to be [taxable] compensation paid to A Co for cutting the timber. ...
Administrative Policy summary

8 July 2013 Interpretation Case No. 145134 -- summary under Subsection 232(3)

. [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...
Administrative Policy summary

19 June 2015 STEP Roundtable, Q. 10 -- summary under Paragraph (b)

Upon completion of the estate administration, a ½ share of the residue (now all cash) is paid (as required under the will) to a resident trust (the "Son's Trust") for the benefit of the testator's non-resident son. ...
Administrative Policy summary

3 February 2014 Interpretation 126057 -- summary under Subsection 13(1)

. If the contracting address of the recipient is not obtained, the business address of the recipient that is most closely connected with the supply would be the obtained business address of the recipient in Canada that the supplier has the most contact with and that the supplier mostly uses in connection with that supply.... ...
Administrative Policy summary

18 November 2014 TEI Roundtable, Q. E.4 -- summary under Subsection 164(1)

For example, when: all returns have been filed up to the date of dissolution, the articles of dissolution indicate that the corporation will distribute its assets to the shareholder(s) after satisfying its creditors, and immediately prior to the dissolution, it was owned by a sole shareholder and it has been determined that the shareholder is the rightful owner of the funds and the sole shareholder completes and returns a signed "Release and Indemnification" form to the CRA; or it was owned by multiple shareholders and a legal representative, as defined in Section 248(1) of the Income Tax Act, has been appointed by the shareholders, to act on their behalf and the appointed legal representative completes and returns a signed "Release and Indemnification" form to the CRA. ...

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