Search - 报销 发票日期 消费日期不一致
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Technical Interpretation - Internal
24 May 1995 Internal T.I. 9505086 - ART XI(3)(e) Canada-U.S. Income Tax Convention
Senécal Appeals & Referrals Division (613)957-9796 Headquarters-Appeals Directorate Attention:Neil Wilson 950508 XXXXXXXXXX This is in reply to your memorandum of February 23, 1995, wherein you request our comments regarding the income tax implications arising out of the following fact situation: XXXXXXXXXX is a United States corporation which is not resident in Canada for the purposes of Part I of the Income Tax Act (the "Act"). ...
Technical Interpretation - Internal
7 June 1995 Internal T.I. 9413016 - EMERGENCY HOME FOR CHILDREN IN CARE OF SOCIAL SERVICES
Her home is maintained for the use of up to 4 foster children & thus the income is exempt June 7, 1995 VANCOUVER TAX SERVICES HEADQUARTERS Audit Division A. ...
Technical Interpretation - Internal
6 June 1995 Internal T.I. 9502987 - WORK SPACE IN THE HOME
Item # 10(a) of the prescribed form T2200 simply asks the employer whether the employee was required under a contract of employment to use a portion of his or her home. ...
Technical Interpretation - Internal
10 August 1995 Internal T.I. 9507937 - TUTORING COSTS AS A MEDICAL EXPENSE
Principal Issues: whether fees paid to a tutor qualify as a medical expense Position TAKEN: no Reasons FOR POSITION TAKEN: cost of tutor not elibigle for tution or medical expense tax credit in certain circumstances, 118.2(2)(e) provides for care & training at a school, institution or other place but using the principle of ejusdem generis, the home of a tutor will not qualify as an "other place" August 10, 1995 Ottawa Tax Services Headquarters Client Assistance Division A. ...
Technical Interpretation - Internal
28 July 1995 Internal T.I. 9513397 - CLERGYMAN'S DEDUCTION - RELIGIOUS ORDER
Principal Issues: whether the taxpayer was entitled to a deduction under para 8(1)(c), & more particularly whether the organization which appointed him was a religious order Position TAKEN: no Reasons FOR POSITION TAKEN: question of fact: the organization in question is more a non-profit organization with humanitarian objectives then a religious denomination July 28, 1995 Toronto Centre Tax Services HEADQUARTERS Appeals D. ...
Technical Interpretation - Internal
28 July 1995 Internal T.I. 9513997 - FOR ADMIN OF XXXXXXXXXX
Principal Issues: whether the taxpayer was entitled to a deduction under para 8(1)(c), & more particularly whether the religious organization which appointed him was a religious denomination Position TAKEN:no Reasons FOR POSITION TAKEN: question of fact: the religious organization in question is more XXXXXXXXXX than a religious denomination July 28, 1995 XXXXXXXXXX Tax Services Income Tax Rulings and Office Audit Interpretations Directorate A. ...
Technical Interpretation - Internal
1 September 1995 Internal T.I. 9417496 - PRINCIPAL RESIDENCE PROVISIONS
Files 920244, 920894, and 921589 contain position which will be superceded by the position contained in this memo and an opinion being issued in file # 950769 At issue is whether or not someone loses their right to designate a property as their principal residence if a property was deemed to have been their principal residence as a result of 40(4). ...
Technical Interpretation - Internal
30 August 1995 Internal T.I. 9517386 - CLASS 24
Our understanding of the facts are as follows: XXXXXXXXXX Pursuant to clause (b)(iii)(C) of class 24 of the Regulations a necessary factor that must be fulfilled by the taxpayer so that the asset qualifies for inclusion in the class, is that the taxpayer must have "... carried out operations at the site in Canada at which operations have been carried on by him from a time that is before 1974,... ...
Technical Interpretation - Internal
13 July 1995 Internal T.I. 9514247 - INTERNAL CRYSTALLIZATION, LEGAL COSTS
It is our view that this intention is evidenced in the paragraph by the reference ".., except to the extent that it is deemed by section 84 to be a dividend. ...
Technical Interpretation - Internal
28 September 1995 Internal T.I. 9524347 F - COMPLÉMENT DU DOSSIER XXXXXXXXXX
En effet, les loyers étant payables le premier jour du mois, le fonds de roulement est supérieur le lendemain d'un montant d'environ XXXXXXXXXX $. ...