Search - 报销 发票日期 消费日期不一致

CRA responded: (a) … [Such] a management or administrative service would typically include managing or administering the day-to-day business and affairs of the partnership. This could include, for example, organizing, monitoring, planning and coordinating the activities of the partnership, making decisions and directing resources to assist the partnership in achieving its defined objectives, as well as maintaining records, and preparing reports. … (b) … The CRA recognizes that there are various methods that may be used and the appropriateness of any valuation methodology used in a particular case is a matter of valuation principles and practice. … [T]he FMV of a supply of a management or administrative service may not necessarily always correspond to the consideration paid for such a service. … General partners can use whichever method they would like to determine FMV. ...

Postponement of collection action can be requested when the following conditions are met: • all associated accounts must remain current with filing/remitting requirements; • all disputed amounts have not already been collected by the taxpayer; • the business must be in good financial order during the period of the objection and/or appeal; • the taxpayer must submit all relevant information that would support vacating the assessment and Appeals is confident that the assessment will be vacated. ...

… Once an eligible employer has determined that it has experienced the required reduction in revenue for a particular claim period, it is automatically considered to have experienced the required reduction in revenue for the immediately following claim period (deeming rule). As a result, the employer does not have to make this determination again for that next claim period …. … In a situation where the eligible employer, subsequently determines that it actually experienced the required reduction in revenue, without applying the deeming rule, for the second claim period- April 12 to May 9, 2020, the eligible employer will be considered to have experienced the required reduction in revenue for that third claim period because of the deeming rule that can now be applied to the third period …. ...

(b) … If a particular supply meets the requirements of both sections 17 and 18, the supplier must make an election under both sections to ensure that the supply will not be exempt under either of these sections. … [However] sections 17 and 18 are generally mutually exclusive and would not apply to the same supply of a membership. ... (c) … It would be unwieldy to require a supplier to complete a separate form in respect of every supply. Therefore, the Minister has approved a form that will allow a supplier to make an election indefinitely, until the supplier chooses that it no longer wants the election to apply … [by] complet[ing] Section D of the relevant form. … On completion of Section D, the supplier is no longer considered to have made an election in respect of any supplies of memberships as of the effective date of the revocation. ...

. … ParentCo is still a separate legal entity and, as such, is a separate person with its own BN. … SubCo would no longer exist as a separate person. As a result, its BN must be cancelled, including its GST/HST program account. … ParentCo will be required to obtain its own GST/HST account number under its existing BN where it is a registrant for GST/HST purposes. … According to the Regulations, the application of section 148 is a prescribed purpose with respect to section 272 of the ETA. ... This means that ParentCo would be required to take into account SubCo’s consideration from taxable supplies over its previous four calendar quarters when determining whether it is required to register for GST/HST purposes. … Under subsection 240(2.1), ParentCo would be required to apply for GST/HST registration before the thirtieth day after the day it makes its first taxable supply in Canada. ...

After indicating that “one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership … to any third party at the Builder’s request (for example, to the Home Buyer …),” CRA stated: [P]rovided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. ...

RC1 Request for a Business Number and Certain Program Accounts-- summary under Subsection 240(2.1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(2.1) Different form for SLFIs Do not use this form if both of the following apply to you: • You are a selected listed financial institution (SLFI) for goods and services tax/harmonized sales tax (GST/HST) purposes or Quebec sales tax (QST) purposes, or both • You want to register for GST/HST and QST purposes or you are already registered for GST/HST purposes and want to register for QST purposes only. ... Assignment of BN to federal corporations or participating provincial corporations You must have a BN if you only want to register for program accounts. • To register for additional payroll deductions, information return, import-export, or charity program accounts, fill in another part C, E, F, or G, as applicable, of another form RC1 and attach it to this form. • You do not need to fill in Part D if you incorporated your business federally or with a province which has partnered with the Canada Revenue Agency (CRA). ... " Corporation income tax (RC)." [This link states: If you incorporate by submitting Form RC1, Request for a business number and certain program accounts, or with the province of Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Saskatchewan, Prince Edward Island, or with Innovation, Science and Economic Development Canada, you should receive a notice confirming your nine-digit BN and a summary of your CRA program accounts by mail.] ...

In this case, the following rules apply: • Because you are considered to have made a taxable sale of the real property, you can claim an ITC equal to the basic tax content of the property just before the election took effect. This means that you can now claim an ITC for all or part of the GST/HST that you paid, or that was payable, on your last acquisition of the property (for example, when you originally bought, or last self-assessed on, the property), and on any improvements you made to it, that you could not previously recover. • You have to report the tax you are considered to have collected on your deemed sale on your GST/HST return for the reporting period in which the deemed sale occurred. • You can claim an ITC for the GST/HST you are considered to have paid on your deemed purchase to the extent that you use the real property in your commercial activities. This is because the primary use rule that you would normally use to determine your ITCs for a purchase of real property does not apply … ...

CRA responded: The following responses assume that where an arrangement is described as a joint venture in the question it has the characteristics of a joint venture as delineated in … P-103 …. ... With respect to the facts in this question: • The transfer by A to B of 25% interest would not meet the criteria for a section 167 election. • Assuming that B is transferring to C its entire interest when it transfers its 85% share, and that the supply is not from a registrant to a non-registrant, the supply would qualify for a section 167 election. • The transfer by A to C of its remaining entire 15% interest may qualify depending on the facts of the situation. ...

. … … [T]he Service Agreement provides, in part, that any notice or other communication to the Council shall be delivered or sent to:[…][Contact information of the Council]. … Under the rules above, the place of supply of the services supplied under the Service Agreement is [Province X]. To be a “practitioner” for purposes of the exemption in section 7.1 of Part II of Schedule V, paragraph (b) of the definition of “practitioner” provides that you must be registered with the regulatory body or professional college for dietitians practising in the province in which the service is supplied. … ...