Search - 报销 发票日期 消费日期不一致

In rejecting the Association’s submission that it collected its fees as Society membership dues as agent for the Society notwithstanding a statement in the Society’s by-laws that: “On behalf of the Society membership, […] [Districts, such as the Association,] shall pay to the Society an annual fee based on a per capita rate for each of its […] Members,” CRA confirmed its statements in a previous ruling letter to the Association that: [T]he bylaws of the [Society] provide no liability to the individual members to pay membership dues to [Society]. In particular, pursuant to section […] of the [Society]’s bylaws, the [District] organizations have the obligation to pay an annual fee to the [Society]. Although the amount of this fee is calculated based on the number of individual members, the individual members are not liable to pay this fee to the [Society]. … Therefore, the value of the consideration for [the Association]’s supplies of memberships is the entire amount charged by [the Association] to the individual members. ...

CRA stated: The … Priority Distribution is … a payment to [the manager] for performing the day-to-day supervision, management and operation of the Nursing Home [and it] is supplying these services to the participants in the joint venture. … [The manager] is reimbursed by the joint venture for the wages and salaries it pays to its employees. [The manager] makes a supply to the joint venture of the services of these employees [and] … is supplying these services to its co-participant [the charity]. ...

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed A proposed GST/HST amendment would zero-rate the supply of an ovum – which would have the effect of rendering the importation of an ovum as a non‑taxable importation. ... Respecting the application of the ovum amendment, for example, CRA indicates: [S]uppliers can stop charging GST/HST on supplies of human ova in accordance with the proposed amendment as of March 20, 2019. … [C]onsistent with its standard practice, the CRA is administering this measure on the basis of the proposed amendment [and similarly re … However, the CRA cannot pay a rebate for an amount paid in error as or on account of tax until the proposed amendment becomes law. A supplier who has charged or collected GST/HST on human ova supplied after March 19, 2019, must include that amount in the calculation of their net tax on their GST/HST return …. ...

. … [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. However … [t]he CRA is under no obligation to accept the value used by the general partner if it is determined to be over or under valued but it will consider the general partner’s FMV determination …. ...

. … For example, in the case of an annual bonus paid by an eligible employer to an eligible employee, it would generally be reasonable to consider that the annual bonus was earned throughout the fiscal period to which it relates. ... It would also be reasonable, for purposes of computing baseline remuneration, to calculate the average weekly eligible remuneration by dividing the bonus amount by the number of weeks included in the period to which it relates …. [Q.17-6] Apportionment of commissions To determine whether a commission payment is in respect of a specific week, it is necessary to review the complete set of facts pertaining to a particular situation, including the employment contract … [and] practices specific to a particular industry …. ...

When funds are: • held on deposit, whether under a TFSA or other arrangement, those amounts are owed by the financial institution (FI) to the depositor and are subject to attachment (RTP); • paid out of a trust arrangement following the direction of the customer or out of an annuity as per the terms of the contract, the funds would be attachable at that time. ... When the TFSA was: • set up as a bank account, send an RTP; • established in any other form, you will need a Writ of Seizure and Sale to seize the funds. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 13(4.1)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(4.1)- Paragraph 13(4.1)(b) Similar business categories 1.41 …[T]wo businesses will be considered to be similar if they both fall within the same one of the following categories: merchandising- retailing and wholesaling; farming; fishing; forestry and forest products; extractive industries, including refining; financial services; communications; transportation; construction, including subcontracting; and manufacturing and processing. 1.42 … [W]here a business falls into more than one, a similar business will be one that falls into any one of these categories in which the business operates. ... As a result, if the plywood plant is sold, any business that also falls under the forestry and forest products or manufacturing and processing categories will generally be considered a similar business …. 1.43 A taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a similar business. … Similar services businesses 1.44 Service industries, such as hotels, restaurants, repairs, professional services, barber and hairdressing shops, funeral parlours, laundries, real estate agencies, tourism, and entertainment, are not included in the general business categories referred to in ¶1.41, because most of these industries are too varied and different to permit categorization. … [S]imilar business will generally be interpreted in a reasonably broad manner. ...

Also describes how a corporate shareholder which files electronically is to provide the required information, and states that a letter filed by a taxpayer with a paper return should contain: ◦ written notification that the shareholder is electing to defer tax relating to the distribution of spin-off shares from a U.S. (or other foreign) corporation, including a description of both the original and spin-off shares; ◦ the number, cost amount otherwise determined, and fair market value of the client's original shares, both immediately before the distribution and after the distribution; and ◦ the number and fair market value of the spin-off shares immediately after distribution. ...

. … In this case, the CRA would treat 90% of the claim under Category 1 and the other 10% would likely fall under Category 2. ... CRA responded: VDP applicants are required to submit information for the 4 calendar years before the date the application is filed for applications processed under Category 1 or Category 2 … [and] would only be expected to include information and payment of the estimated tax owing for 4 calendar years before the date the application is filed even if the error was made for more than the 4 calendar years prior to the date of filing. … If an application that was believed to fall under Category 1 (GST/HST wash transaction) or Category 2 (General program) is reclassified, in part or in whole to Category 3 (Limited program) by the CRA, the applicant will be required … to pay the additional taxes …. ...

Where, upon completion of a course, documentation is provided that does not attest to the competence of an individual to practise or perform a trade or vocation but merely states that the individual has taken and passed the course, the course will not qualify for zero-rating under section 18 …. ... Corporation Tree-NB invoices the non-resident company and not the employee. … While stand-alone industry safety courses may be beneficial, and in some cases a job requirement, on their own they would not be considered to lead to an occupation. As the course offered by Corporation Tree-NB does not lead to a diploma or certificate attesting to the competence of the individual to practice a trade or vocation, the course is not zero-rated under section 18 …. ...