Search - 报销 发票日期 消费日期不一致

. … [A] requirement that the fees related to the review and approval of a land development agreement be paid in full to the regional municipality prior to the issuance of a permit by a local municipality is not evidence, in and of itself, that the services provided by the regional municipality in connection with those fees are elements of a single supply. Further, many of the fees identified are payment for a separate supply, e.g., approval of a plan amendment or a condominium conversion. … The review by the regional municipality of the land development agreement is a separate activity from the issuance of a permit by a local municipality. ...

. … [T]he “particular reporting period” [is] the reporting period in which the ITC or deduction first became claimable. …[T]he auditor…may… request further documentation, including in the case of GST/HST rebates, copies of the actual rebate forms. … HQ has reminded auditors and examiners of the above requirement…. ...

14 October 2016 Interpretation 170549-- summary under Subsection 273(1) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(1) Westcan test for JV, co-tenancy was JV ACo and BCo, which were co-tenants of a property in construction held through a Nominee made a s. 273 election in year X + 2 designating ACo as the operator, and describing the JV activities as being the development and construction of real property. Their co-tenancy agreement was entered into in Year X and their agency agreement with the Nominee was entered into in Year X + 2. ...

14 October 2016 Interpretation 170549-- summary under Agency Summary Under Tax Topics- General Concepts- Agency co-owners required to report pro rata portions of sale made by their agent ACo and BCo, which were co-tenants of a property in construction held through a Nominee, signed an agency agreement in which Nominee was designated as the agent of ACo and BCo and which provided that the Nominee was the authorized agent and representative of ACo and BCo including for the claiming of input tax credits – and the Nominee made such claims prior to the end of the period of administrative tolerance expressed in GST/HST Notice 284. In rejecting this approach, CRA stated: [I]t is the principal who is entitled to claim any input tax credits on the supplies acquired by the agent on behalf of the principal. … The statement in the agency agreement stating that the Nominee will claim ITCs on inputs purchased in its capacity as agent does not extinguish ACo and BCo’s potential right to claim the ITCs under the ETA, nor does it result in the Nominee being entitled to claim ITCs. ...

The circumstances of these supplies can be differentiated from the supply of [the Assessment] in that the purpose for these supplies is the examination by the physician or the review of a report by the physician. […] [The Assessment] supplied by [ACo], […] is a multi-disciplinary assessment conducted by a number of different service providers including…. ...

CRA responded: [I]n the context of section 149 … the CRA considers that "principal" refers to the person's chief or main business activity. … Some factors to be considered, but not limited to, include: the total number of supplies made and the total value of the revenue received from supplies made in each business activity; the relative value of the assets employed in each business activity; the commercial practices of the person, including the time, attention, and efforts expended by the employees, managers, or corporate officers in each business activity; and the terms of any partnership agreement if the person is a partnership, or corporate objects in the case of a corporation. ...

CRA responded: [U]nder subsection 175(1) … Great Law Firm LLP would be deemed to have paid, at the time the reimbursement is paid to the partner, tax in respect of the supply of the MacBook Pro equal to the total amount of tax reimbursed. ... [T]he comments provided [above] would also apply to a reimbursement made … to its employee. ...

. … Application may also be made by telephone, provided all required information is available. … Branches do not have separate existence 4. ...

Although the [children’s programs] are enriched by recreational and athletic activities … the primary purpose of the programs is to provide care and supervision to children 14 years of age and under. Therefore, the Corporation’s supplies made under the […] summer day camps and after-school programs are exempt from GST/HST. ...

Therefore … subparagraph 173(1)(d)(i) would not apply …. ...