Search - 报销 发票日期 消费日期不一致

16 November 2015 External T.I. 2015-0595041E5- Mutual Fund Trusts & 108(2)(a)(i) CRA Tags 108(2)(a) 132(6) Principal Issues: Does CRA still consider a redemption schedule more than once annually satisfying 108(2)(a)(i)? ... Yours truly, Phil Kohnen Manager, Trusts Section I Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

26 May 1995 External T.I. 9513715- CREDITOR LIFE INSURANCE & CDA Unedited CRA Tags 89(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Yours truly, Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

20 January 2000 External T.I. 9932435- DEDUCTIONS FROM OAS & CPP BENEFITS Unedited CRA Tags 8 5(2) 3(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Whether employment expenses can be deducted from OAS & CPP benefits. ...

18 October 1999 External T.I. 9919265- STOCK OPTIONS & CCPC Unedited CRA Tags 7(1.1) 110(1)(d.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Whether CCPC options or shares are still eligible for 7(1.1) & 110(1)(d) or (d.1) treatment Position: Yes Reasons: Wording of 7(1.4) and 7(1.5) XXXXXXXXXX 991926 S. ...

6 May 1993 External T.I. 9301125 F- Former Business Property — Same Business Unedited CRA Tags 44(5)(b), 248(1) Former business property   XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Replacement Property This is in reply to your facsimile of January 15, 1993 in which you requested our opinion on the application of the replacement property rules in the Income Tax Act (the "Act"). ...

12 October 1995 External T.I. 9512485- PARTITION OF ACCOUNTS RECEIVABLES & OTHER FUNGIBLES. ... Principal Issues: APPLICATION OF 248(20) & 248(21) WHERE THE SUBJECT PROPERTY IS ACCOUNTS RECEIVABLES INVENTORY AND OTHER LIKE PROPERTY COMPRISED OF NUMEROUS INDIVIDUAL PROPERTIES? ...

14 November 2002 External T.I. 2002-0136625- Compound interest & thin capitalization Unedited CRA Tags 18(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Yours truly, Olli Laurikainen for Director International & Trusts Division Income Tax Rulings Directorate ...

1 May 2018 External T.I. 2018-0743031E5- Work in progress / Travaux en cours 1 May 2018 letter to APFF, 2017-0709101E5 F is essentially the same and is summarized by us at that node Unedited CRA Tags 34, 10(1), 10(4)(a) Principal Issues: 1) Several questions regarding work in progress cost determination. 2) How should the value of a professional’s work in progress be determined where the work is performed on a contingency basis? / 1) Plusieurs questions portant sur la détermination du coût des travaux en cours. 2) Comment détermine-t-on la JVM des travaux en cours résultant d’une entente mettant en cause des honoraires conditionnels? ... It may, in some cases, be nil. / 1) La détermination du coût est une question de fait. ...

None of the OwnerCos has a permanent establishment in Canada as defined under Article V of the Canada-US Tax Convention (the “US Treaty”) or Article 5 of the Canada – UK Tax Convention (the “UK Treaty”). 6. ... Given the above analysis, it is our view that Fee #2 is a “royalty” as it qualifies as “payments … for the use of, or the right to use, any … information concerning industrial, commercial or scientific experience…” as defined under paragraph 4 of Article XII of the US Treaty. ... As discussed above, we have concluded that Fee #2 paid by CanCo to OwnerCo is for “the use of, or the right to use, … any information concerning industrial, commercial, or scientific experience…”. ...

26 May 2010 External T.I. 2009-0342121E5- rooftop solar panels & class 43.2 Principal Issues: 1.will rooftop solar panels & equip qualify for inclusion in class 43.2 under various scenarios subject to the specified energy rules limiting CCA. 2.will claiming cca jeopardize the principal residence exemption? Position: 1.provided expenses incurred for the purpose of producing income & other conditions of the class are met; 2. the principal residence claim will not be jeopardized provided no cca claim is made on the building itself & the earning of income is ancillary to the residence use. Reasons: 1. 1102, 1100(25); 1100; 2.45(2) & IT120-r6 XXXXXXXXXX 2009-034212 Lena Holloway May 26, 2010 Dear XXXXXXXXXX: Re: Technical Interpretation Request regarding Capital Cost Allowance of Solar Panels This is in response to your facsimile correspondence of September 24, 2009 requesting our views as to the income tax treatment of the purchase of solar photovoltaic systems under various hypothetical scenarios. ...