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Technical Interpretation - External summary

7 November 2001 External T.I. 2000-0038195 - Indefeasible Vesting of Interest in Trust -- summary under Paragraph (g)

7 November 2001 External T.I. 2000-0038195- Indefeasible Vesting of Interest in Trust-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) indefeasible vesting but no disposition where sole beneficiary Respecting the application of the 21-year deemed disposition rule where a trust has one beneficiary that is neither the settlor nor the settlor's spouse, CRA stated: Specifically excluded [from the rule] is a trust all interests in which have vested indefeasibly at the time the rule would apply, other than those trusts listed in subparagraphs (g)(i) to (vi) …. ...
Technical Interpretation - External summary

9 August 2017 External T.I. 2017-0709351E5 - Interaction between subsections 98(1) and 116(5) -- summary under Subsection 116(5)

9 August 2017 External T.I. 2017-0709351E5- Interaction between subsections 98(1) and 116(5)-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) gain from negative partnership interest ACB not subject to s. 116(5) Where a partnership has ceased to exist, any negative adjusted cost base to a taxpayer (including a non-resident) of its partnership interest at the end of the fiscal period is deemed to be a capital gain from a disposition of its interest in the partnership but its partnership interest is not deemed to be disposed of to the partnership (cf. s. 84(9).) ...
Technical Interpretation - External summary

26 March 2008 External T.I. 2007-0224771E5 F - Sommes reçues en échange de références de clients -- summary under Subsection 200(1)

After noting that such amounts likely would not be taxable to the recipients if they were provided “on a one-off or very irregular basis as this activity does not sufficiently occupy the taxpayer's time and effort,” CRA stated: [N]o information slip is required to be made where the amount paid to a taxpayer is not taxable. ...
Technical Interpretation - External summary

21 April 2008 External T.I. 2007-0220471E5 F - Excessive Capital Dividend and 220(3.2) -- summary under Subsection 184(4)

Furthermore, we do not intend to propose to the Department of Finance that the conditions for making an election by virtue of subsection 184(3) be changed, since there is a valid legislative alternative …. ...
Technical Interpretation - External summary

6 May 2008 External T.I. 2007-0254661E5 F - Partie B Medicare -- summary under Non-Business-Income Tax

More detailed information on Medicare coverage is available in Medicare & You at www.medicare.gov. ...
Technical Interpretation - External summary

1 May 2008 External T.I. 2007-0250141E5 F - Crédit pour la création d'emplois d'apprentis -- summary under Eligible Apprentice

. [S]ince an apprentice must hold an apprenticeship competency certificate to work in the construction industry in Quebec, we believe that the issuance of the first apprenticeship competency certificate is an indicator of the beginning of an apprentice's apprenticeship. ...
Technical Interpretation - External summary

29 May 2008 External T.I. 2007-0262591E5 F - Remboursement de sommes versées par erreur -- summary under Paragraph 8(1)(n)

However, the insurer discovered that, in the interim, the taxpayer had started receiving a pension under the Quebec Pension plan and also had been granted a retroactive pension by the employer so that it claimed reimbursements of the disability payments it had made for the same periods. ...
Technical Interpretation - External summary

13 June 2008 External T.I. 2008-0270721E5 F - Allocations pour l'usage d'un véhicule à moteur -- summary under Subparagraph 6(1)(b)(vii.1)

13 June 2008 External T.I. 2008-0270721E5 F- Allocations pour l'usage d'un véhicule à moteur-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) allowance for employees’ to return to work after regular shift to be on call was taxable In accordance with their collective agreement, employees are paid an allowance as compensation for the use of their personal vehicle when the employee is on call and must return to work after the employee’s regular shift in order to respond to calls with the amount of the allowance based on what would have been disbursed had the employee instead returned to work by taxi. ...
Technical Interpretation - External summary

15 July 2008 External T.I. 2008-0279271E5 F - Frais de déménagement en cas de faillite -- summary under Subsection 128(2)

15 July 2008 External T.I. 2008-0279271E5 F- Frais de déménagement en cas de faillite-- summary under Subsection 128(2) Summary Under Tax Topics- Income Tax Act- Section 128- Subsection 128(2) as s. 128 is a complete code not covering moving expenses, an individual could deduct moving expenses incurred in the stub pre-bankruptcy year from bankruptcy year income In finding that moving expenses incurred by an individual in the year that was deemed to end immediately before the day of bankruptcy could be deducted in the taxation year commencing with the bankruptcy and ending on December 31, CRA stated: [S]ection 128 is a complete code and there are no rules preventing an individual from deducting qualifying moving expenses in the year of bankruptcy where those expenses were incurred in the year immediately preceding the bankruptcy. ...
Technical Interpretation - External summary

29 August 2008 External T.I. 2007-0257661E5 F - Allocation pour frais de déplacement -- summary under Subparagraph 6(1)(b)(vii.1)

CRA stated that where the “travel is between the Corporation’s place of business and another place of work such travel is not of a personal nature” (and also noted that an allowance paid in accordance with the Reg. 7306 rates is generally considered reasonable). ...

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