Search - 报销 发票日期 消费日期不一致
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Technical Interpretation - Internal
13 April 1994 Internal T.I. 9400887 - COMPUTER SOFTWARE
When purchasing the assets of a computer software business, possible allocations of a lump sum purchase price may be for: application software (including all rights attached thereto)- class 12 goodwill- eligible capital expenditure trademarks- eligible capital expenditure special technology & /know-how & copyrights- part of software costs (class 12) customer lists- eligible capital expenditures software available for sale- inventory A valuation may reveal that the amount of the purchase price assigned to class 12 assets has been overstated. ...
Technical Interpretation - Internal
20 April 1994 Internal T.I. 9408206 - TAX EXEMPT EMPLOYERS WHICH QUALIFY FOR UI CREDIT
Position TAKEN: Proposed subsection 126.1(1) restricts the UI Credit to those employers that qualify for exemption under paragraphs 149(1)(e), (f), (i), (j), (k), (l), (m), (n), (o.3) & (t). ... Likewise it is not only the government related employers which are exempt under paragraphs 149(1)(c) & (d) that do not qualify for the UI Credit but all the other non-government type of employers described in items 11 to 29 above would also not qualify. ...
Technical Interpretation - Internal
1 September 1994 Internal T.I. 9331436 - MEANING OF PROPORTION IN 126(1)(B)
.), in dealing with the term proportion as it appeared in Regulation 701(1)(a) at the time, the court noted at 5386 that: "... ... ". Since the term "fraction" is defined in le Petit Larousse to be "partie d'un tout" (part of the whole), the French version of the Act seems quite clear that the proper interpretation for the term "proportion" in paragraphs 126(1)(b) and 126(2.1)(a) is that found in Oxford's which is "a portion or part in relation to the whole; a comparative part, a share; occas., a portion, division or part". ...
Technical Interpretation - Internal
8 March 1996 Internal T.I. 9530166 - NON-RESIDENT BENEFICIARIES AND SECTION 216
., a minimum Federal tax rate of 17% plus additional Federal rate of 52% on basic Federal tax = 17% x 152% = 25.84%- 2- ...
Technical Interpretation - Internal
6 May 1996 Internal T.I. 9608907 F - FRAIS DE RESILIATION DE BAIL - DÉMÉNAGEMENT
Par ailleurs, si le bail entre la cliente et le propriétaire du logement a été résilié en XXXXXXXXXX par le paiement de XXXXXXXXXX $, ce montant serait alors admissible à titre de frais de déménagement. Par contre, si la somme de XXXXXXXXXX $ n'a pas été payée pour résilier le bail, elle ne serait pas admissible à titre de frais de déménagement. ...
Technical Interpretation - Internal
25 September 1996 Internal T.I. 9628306 - CORPORATIONS OWNED BY INDIAN BANDS
September 25, 1996 John Fennelly HEADQUARTERS Program Management & J.D. Brooks Operations Section 957-8953 Small & Medium Business Enterprises Division Audit Directorate Attention: Luisa Guyan 962830 Corporations Owned by Indian Bands This is in reply to your request of July 31, 1996 in which you requested our views on the taxability of incorporated entities owned by Indian bands. ...
Technical Interpretation - Internal
18 November 1996 Internal T.I. 9604066 - CORPORATION OWNED BY INDIAN BAND
November 18, 1996 John Fennelly HEADQUARTERS Program Management & J.D. Brooks Operations Section Small & Medium Business Enterprises Division 957-2103 Audit Directorate Headquarters 960406 XXXXXXXXXX This is in reply to your request of January 22, 1996 in which you requested our views on the application of paragraph 149(1)(d) and subsection 149(10) of the Income Tax Act (the "Act") to XXXXXXXXXX (the "Taxpayer"). ...
Technical Interpretation - Internal
26 November 1996 Internal T.I. 9625286 - DEC 1995 INCOME RESERVE AND BANKRUPTCY OF A PROFESSIONAL
& does the change in fiscal period legislation affect Dept's Dec 91 policy to permit a change in fiscal period to coincide with the bankruptcy? ... Oulton Section Chief Business, Property & Personal Section Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...
Technical Interpretation - Internal
10 December 1996 Internal T.I. 9639060 - TERMS OF REPAY FOR SH LOAN EXEMPT BY REASON OF THE ACT
Principal Issues: what constitutes reasonable terms of repayment for a shareholder loan exempt by reason of 15(2.3) Position: as long as the terms & conditions of a loan to a shareholder are the same as that for the public at large, the terms of repayment associated with such a commercial transaction will normally be treated as reasonable for the purposes of 15(2.3)-this includes revolving credit instruments which do not make provision for repayment of the entire loan but require minimum payments-however loans that are not exempt by reason of 15(2.3) will only be exempt under 15(2.4) or (2.5) if the terms for full repayment of the loan are set out at the time the loan is made Reasons: it is a question of fact as to what is reasonable in a given set of circumstances- for 15(2.4) & (2.5) loans, it is reasonable that the terms of repayment for the full amount of the loan should be set at the time the loan is made. ...
Technical Interpretation - Internal
17 May 1993 Internal T.I. 9311537 F - Alberta Pension Split on Marriage Breakdown
17 May 1993 Internal T.I. 9311537 F- Alberta Pension Split on Marriage Breakdown Unedited CRA Tags 56(1)(a) May 17, 1993 HEAD OFFICE EDMONTON Personal and General Enquiries and DISTRICT OFFICE Office Examination Section Taxpayer Requests A. Humenuk (613) 957-2134 Attention: Bryant Town Pension Splitting on the Breakdown of Marriage We are replying to your memorandum of April 15, 1993 concerning the reporting of the pension income received by XXXXXXXXXX Reference is also made to our telephone conversations of April 26 and May 11, 1993 (Town/Humenuk). ...