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Technical Interpretation - Internal

16 January 2003 Internal T.I. 2002-0164407 - Interest on Crown Charges

XXXXXXXXXX In order to reverse the effect of the cases of Johnson & Johnson, 94 DTC 6125 (FCA) and Canada Safeway, 98 DTC 6060 (FCA), paragraph 12(1)(x) was amended to add a reference to amounts refunded. ...
Technical Interpretation - Internal

6 July 2000 Internal T.I. 2000-0026587 - COURT AWARDED LEGAL FEES; CHILD SUPPORT

Paragraph 4 of IT-99R5 states that "... if the taxpayer is successful in a legal proceeding, the gross amount of the legal fees which are otherwise deductible must be reduced by any legal costs awarded by the court which are received by the taxpayer. ...
Technical Interpretation - Internal

28 May 2000 Internal T.I. 2000-0025807 - INDIAN BANDS AS PUBLIC BODIES

Position: Reasons: June 28, 2000 Small & Medium Enterprises Division HEADQUARTERS Audit Directorate Karen Power, CA Compliance Programs Branch (613) 957-8953 Attention: Diana Favel 2000-001254 Indians Bands as Public Bodies Performing a Function of Government Further to our recent meeting (Albert/Power/Favel/Mott) we are writing to clarify the Agency's position regarding whether Indian Bands may be considered public bodies performing a function of government in Canada for purposes of paragraph 149(1)(c) of the Income Tax Act (the "Act"). ...
Technical Interpretation - Internal

19 July 2000 Internal T.I. 2000-0026417 - MANDATORY INVENTORY ADJUSTMENT

John Oulton Manager Business, Property & Employment Section III Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch?? ...
Technical Interpretation - Internal

18 January 1991 Internal T.I. 9035207 F - Ontario Farm Start Program

WheelerChiefServices, Public Utilities & Exempt and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch ...
Technical Interpretation - Internal

27 January 1993 Internal T.I. 9234987 F - Dwellings and a Shareholder's Loan

In this regard, the relevant facts and information could include the following with respect to such a determination: (a)     the type of property acquired; (b) the use to which the property was put when the Taxpayer did not inhabit it; (c) the extent that the property is used by relatives and other individuals; and (d) whether rental income has been received. ...
Technical Interpretation - Internal

13 June 1991 Internal T.I. 9110307 F - Meaning of "Benevolent or Fraternal Benefit Society or Order"

13 June 1991 Internal T.I. 9110307 F- Meaning of "Benevolent or Fraternal Benefit Society or Order" Unedited CRA Tags 149(1), 149(3) 7-911030 24(1) This is in reply to your memorandum of April 15, 1991, concerning the tax status of the  24(1) under subsections 149(1) & (3) of the Act. ...
Technical Interpretation - Internal

8 March 1990 Internal T.I. 74719 F - Additional Employer Contribution on Termination of Money Purchase Pension Plan

Kotlar 957-8962 Director   File No. 7-4719 Subject: Treatment of Additional Employer contribution on  Termination of a Money Purchase Pension Plan Your File- ITR 39868 This is in reply to your memorandum of February 8, 1990 prepared by M. ...
Technical Interpretation - Internal

2 May 1991 Internal T.I. 9033137 F - Deductibility of Interest Expense

ClarkChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate Attachment c.c.:  W. ...
Technical Interpretation - Internal

8 February 1990 Internal T.I. 59257 F - Proposed Settlement for Lost Salary

Humenuk   (613) 957-2135 Attention:  Richard Bergeron February 8, 1990 Dear Sirs: Re:  Proposed Settlement for Lost Salary We are responding to your letter of December 14, 1989, concerning a 24(1) In our conversation of February 4, 1990, with Mr. ...

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