Search - 报销 发票日期 消费日期不一致

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Technical Interpretation - External summary

27 July 2010 External T.I. 2010-0364841E5 F - Questions relatives à une séparation -- summary under Paragraph 118(1)(a)

CRA stated: The courts have held that it is possible for two spouses to live separate and apart due to marriage breakdown, even if they still live under the same roof, in the following circumstances …: the spouses occupy separate bedrooms; the absence of sexual relations between the spouses; little, if any, communication between the spouses; no domestic services between the spouses; the spouses eat their meals separately; the spouses have no social activities in common. [T]he existence of a joint account and the payment of joint expenses does not prevent you and your spouse from living separate and apart due to the breakdown of your marriage on XXXXXXXXXX 2009. ...
Technical Interpretation - External summary

26 July 2010 External T.I. 2010-0368991E5 F - CIAPH - Société de personnes -- summary under Qualifying Home

. …. [This] position could apply in the two hypothetical situations …. ...
Technical Interpretation - External summary

23 June 2010 External T.I. 2010-0365581E5 F - Règles d'attribution de l'article 74.2 -- summary under Paragraph 74.5(1)(c)

. [T]he condition in paragraph 74.5(1)(c) would be satisfied where an individual's capital property is not transferred in the circumstances described in subsection 73(1.01). ...
Technical Interpretation - External summary

12 July 2016 External T.I. 2014-0560361E5 - Cdn beneficiary of US living trust -- summary under Subsection 126(1)

. Where the grantor can change the terms of, or completely revoke the trust during their lifetime, they effectively retain control of the trust assets. Given this retention of control, it is our understanding that…any income generated by the trust would be reported by the grantors of the trust on a personal U.S. income tax return. Where U.S. tax is paid on trust income by the grantors, a foreign tax credit may be available to the grantor/beneficiary in Canada. ...
Technical Interpretation - External summary

9 March 2017 External T.I. 2017-0689241E5 F - Avantages imposables relatifs aux automobiles ou autres véhicules -- summary under Subsection 6(2)

. [I]f a vehicle that does not meet the definition of automobile, there is still a benefit to the employee under paragraph 6(1)(a) where the vehicle is used for personal purposes. ...
Technical Interpretation - External summary

23 April 2009 External T.I. 2008-0301241E5 F - Fiducie d'invest. à participation unitaire-75(2) -- summary under Subsection 248(28)

In a particular case the CRA could extend this position so that no reduction to the ACB of a beneficiary's capital interest would be made by virtue of subparagraph 53(2)(h)(i.1). [W]e have doubts as to whether paragraph 248(28)(a) can be invoked to ensure that no negative adjustment can be made to the ACB of the taxpayer's capital interest to prevent double taxation. ...
Technical Interpretation - External summary

11 May 2009 External T.I. 2009-0307941E5 - Back to Back Loans provisions -- summary under Subsection 118.1(17)

We have brought this result to the attention of the Department of Finance …. …[T]he Act does not provide for the reinstatement of a gift in the event the property used by the donor or person not dealing at arm's length with the donor is returned to the charity. ...
Technical Interpretation - External summary

2 July 2009 External T.I. 2009-0319211E5 F - T5008 : Contrat d'opération à terme (Futures) -- summary under Subsection 230(2)

After stating that a "long or short position in a CGB contract is a ‘security’ under paragraph (f) of the definition [in Reg.] 230(1), CRA stated: [T]he amount to be entered in Box 21 of the T5008 slip entitled "Proceeds of disposition or settlement amount" is $2,600 which is the total proceeds realized by your client as a result of the liquidation of his open position in the 5 CGB contracts. ...
Technical Interpretation - External summary

20 July 2009 External T.I. 2009-0312541E5 F - Allocation pour usage d'un véhicule à moteur -- summary under Subparagraph 6(1)(b)(x)

After noting that T4130 states that when an employer pays an allowance that is a combination of flat-rate and reasonable per-kilometre allowances that cover the same use for the vehicle, the total combined allowance is a taxable benefit and has to be included in the employee's income,” CRA stated: [P]art of the allowance paid to employees is based on a per kilometre rate that is considered reasonable while the other part of the allowance is not related to the use of the motor vehicle there are two allowances. ...
Technical Interpretation - External summary

7 December 2009 External T.I. 2009-0346821E5 F - Crédit d'impôt pour la rénovation domiciliaire -- summary under Qualifying Expenditure

7 December 2009 External T.I. 2009-0346821E5 F- Crédit d'impôt pour la rénovation domiciliaire-- summary under Qualifying Expenditure Summary Under Tax Topics- Income Tax Act- Section 118.04- Subsection 118.04(1)- Qualifying Expenditure expenditures incurred for services or property received during the eligible period can qualify even though the related renovation does not proceed until after that period Regarding the eligibility for the HRTC of expenditures made or incurred by a syndicate of co-owners during the eligible period to acquire property in the same period that will not be used until after the eligible period or of expenditures made or incurred during the eligible period for the development of renovation plans when the plans so developed will not be used until after the eligible period CRA stated: Expenditures made or incurred by a syndicate of co-owners in the eligible period for property acquired in the eligible period will be qualifying expenditures for the HRTC even if the qualifying renovations relating to that property is not carried out until after January 31, 2010. ...

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