Search - 报销 发票日期 消费日期不一致
Results 1631 - 1640 of 1661 for 报销 发票日期 消费日期不一致
Technical Interpretation - External summary
2 April 2025 External T.I. 2019-0818321E5 F - Reverse Earnout -- summary under Paragraph 12(1)(g)
The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...
Technical Interpretation - External summary
18 February 2025 External T.I. 2024-1038891E5 - De facto control -- summary under Subsection 256(5.1)
Further … a personal guarantee of the amount owing under a vendor take-back promissory note by the controlling shareholder of the purchaser corporation would not, where the purchaser corporation has the capacity to make the scheduled payments under the promissory note (and absent any other factors indicative of de facto control), result in the holder having de facto control of the purchaser corporation. ...
Technical Interpretation - External summary
5 April 2000 External T.I. 1999-0004235 F - PERTE AU TITRE D'UN PLACEMENT D'ENTREPRISE -- summary under Subsection 39(12)
Assuming that an amount under the guarantee agreement became payable within 12 months after the time of the cessation of Aco’s business, s. 39(12) applied to all amounts repaid under the guarantee agreement – so that Mr. ...
Technical Interpretation - External summary
22 August 2014 External T.I. 2014-0540751E5 F - Acquisition of control -- summary under Paragraph 256(7)(a)
. … Opco Before the [above] transfers of shares…Opco was controlled by a related group…consist[ing] of either A and B, or Holdco A and Holdco B. ...
Technical Interpretation - External summary
3 January 2014 External T.I. 2013-0514021E5 F - Subsection 55(2) - redemption of shares -- summary under Paragraph 55(3)(a)
. … Our conclusion would be the same if the transactions respecting a freeze of Opco in order to introduce Nephew were part of the series of transactions that included the deemed dividend received by Holdco as a result of the redemption of the Class "D" shares of the capital stock of Opco held by Holdco, as Nephew and Nephew Inc. were related to Holdco, the dividend recipient, by virtue of subparagraphs 251(2)(b)(iii) and 251(2)(c)(ii), respectively. ...
Technical Interpretation - External summary
12 November 2013 External T.I. 2012-0471621E5 F - Moving expenses - eligible relocation -- summary under Eligible Relocation
. … If it is established on the facts that the taxpayer ordinarily occupied Residences 1, 2, and 3, the move from Residence 1 to Residence 2 is considered a relocation, and that from Residence 2 to Residence 3 as a second relocation. ...
Technical Interpretation - External summary
8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules -- summary under Subsection 74.4(2)
…[W]e refer you to… 2002-0147325 …. 2 nd Situation. Same as 1 st situation except that, rather than subscribing for preferred shares of Holdco, Opco declares a dividend on its common shares (held by Mr. ...
Technical Interpretation - External summary
3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income -- summary under Subsection 20(12)
A could under subsection 20(12) opt to claim, in his 2014 Canadian income tax return, an amount of up to $400…[which] would reduce the amount of his “non-business income tax” for 2014 …. ...
Technical Interpretation - External summary
22 November 2011 External T.I. 2011-0420451E5 F - Canadian resource property -- summary under Paragraph (e)
CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...
Technical Interpretation - External summary
19 December 2016 External T.I. 2016-0643191E5 F - Deferred Salary Leave Plan (DSLP) -- summary under Paragraph 6801(a)
In this type of arrangement (or one where the employee only receives advances during the leave – in which case, it is not within the DSLP rules), the employee is entitled to a s. 8(1)(n) deduction as the advances are “repaid” (i.e., out of reduced pay cheques following the return to work). ...