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Technical Interpretation - External summary

21 January 2002 External T.I. 2001-0080325 F - FRAIS DE VOYAGE-BIENS LOCATIFS -- summary under Paragraph 18(1)(h)

CCRA noted that “[s]everal court cases, including Benjamin 54 DTC 357 have determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer and therefore not deductible pursuant to paragraph 18(1)(h).” ...
Technical Interpretation - External summary

27 May 2010 External T.I. 2010-0359491E5 F - Programme Agri-investissement -- summary under Subsection 12(10.2)

The second fund is a "NISA Fund No. 2 " …. Generally, a taxpayer must include in computing income for a taxation year from property by virtue of subsection 12(10.2) the total of all amounts paid to the taxpayer from the taxpayer's NISA Fund No. 2. ...
Technical Interpretation - External summary

31 August 2000 External T.I. 2000-0035675 F - INSTITUT DE RECHERCHE AGRÉÉ -- summary under Clause 37(1)(a)(ii)(B)

31 August 2000 External T.I. 2000-0035675 F- INSTITUT DE RECHERCHE AGRÉÉ-- summary under Clause 37(1)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(B) CCRA requires that a hospital research institute be separate from the hospital In explaining its refusal to accredit an organization, CCRA stated: [A]n organization that provides hospital services and carries out joint scientific research and experimental development (SR&ED) will not come within clause 37(1)(a)(ii)(B) or clause 37(1)(a)(ii)(A) since the organization does not carry on SR&ED activities only. CCRA requires that a hospital's research centre be a legal entity separate from the hospital …. ...
Technical Interpretation - External summary

17 July 2007 External T.I. 2007-0220121E5 F - Lac artificiel - catégorie d'amortissement -- summary under Paragraph (e)

17 July 2007 External T.I. 2007-0220121E5 F- Lac artificiel- catégorie d'amortissement-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 6- Paragraph (e) artificial lake qualifies as a “water storage tank’ Before finding that the costs of creating an artificial lake to be used for a fishing resort should be included in Class 6, CRA noted: Oriole Park Fairways 56 DTC 537 relied on the ordinary meaning of the words "water storage tank"- which includes “a pool or lake, or an artificial reservoir”- to conclude that ponds on a golf course should be capitalized in Class 6 Words and Phrases water storage tank ...
Technical Interpretation - External summary

18 May 2004 External T.I. 2004-0069691E5 F - Incorporation des professionnels -- summary under Section 34

. The election is therefore not permitted …. Words and Phrases accountant ...
Technical Interpretation - External summary

11 July 2013 External T.I. 2013-0490591E5 F - Montant pour une personne à charge -- summary under Common-Law Partner

. In the absence of a complete description we cannot determine whether a conjugal relationship exits …. ...
Technical Interpretation - External summary

25 February 2004 External T.I. 2003-0042461E5 F - Invalidité d'un actionnaire/admin./employé -- summary under Paragraph 6(1)(a)

In addition the payment of premiums would not result in a taxable employee benefit or a taxable shareholder benefit because the corporation is the recipient of the insurance benefits. ...
Technical Interpretation - External summary

30 January 2006 External T.I. 2005-0159331E5 - Long term disability lump sum payments -- summary under Paragraph 6(1)(f)

30 January 2006 External T.I. 2005-0159331E5- Long term disability lump sum payments-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) lump sum in lieu of future benefits under employee disability plan is non-taxable In response to a query as to CRA’s position regarding the taxability of lump sum payments of long-term disability benefits that do not represent arrears, it stated: On the basis of Tsiaprailis taxable amounts under paragraph 6(1)(f) include lump sum settlements that are attributable to disability payments in arrears and accruing to the date of the settlement. However, where an individual receives a lump sum payment in lieu of future benefits that would have been otherwise paid under an employer long-term disability plan, in circumstances such that the payment can reasonably be considered to be proceeds of disposition of an interest in an insurance policy, it is our view that the proceeds are not taxable under paragraph 6(1)(f) of the Act or as a capital gain pursuant to subparagraph 39(1)(a)(iii) …. ...
Technical Interpretation - External summary

24 April 2013 External T.I. 2013-0476561E5 F - Coûts de drainage de terre agricole -- summary under Section 30

CRA stated: "[A]ny amount paid by the taxpayer before the end of the year for …installing a land drainage system” includes the cost of drainage pipes, whether plastic or other material, and the cost of installing these pipes. ... Nevertheless, when a taxpayer leases farmland that the taxpayer owns to someone else "income from a farming business" means that an amount is deductible under that provision only by a taxpayer who carries on a farming business and not by a taxpayer who earns rental income. ...
Technical Interpretation - External summary

26 March 2010 External T.I. 2009-0350821E5 F - Montant assurable et ouvrant droit à pension -- summary under Paragraph 8(1)(c)

. On the other hand, if the pastor of your church holds an office or employment, he or she will be required to include in computing income the value of [the] lodging [but] may be eligible for the clergy residence deduction by virtue of paragraph 8(1)(c) if he or she satisfies both of the following conditions: [s. 9(1)(c) conditions summarized]. ...

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