Search - 报销 发票日期 消费日期不一致

. … Whenever there is insufficient space on the Notice of Objection form to provide facts and reasons for the objection or the assessment information, you can always attach a separate sheet(s). … ...

8 March 2018 CBA Commodity Tax Roundtable, Q.9-- summary under Paragraph 142(2)(a) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(2)- Paragraph 142(2)(a) Incoterms did not govern the place of delivery of goods Company B, a registered resident, agreed to sell tangible personal property (the “Property”) to Company C, an unregistered non-resident, using the Incoterms® 2010 DAP Port of Liverpool, U.K. so that delivery and title transfer was to occur at the U.K. destination – although the parties agreed that Company C was to indemnify Company B if the Property were lost or damaged in transit. ... Our response … would not change if it were established that Company C’s affiliate (and not Company C itself) provided the commercial indemnity in a side agreement. ...

CRA responded: The assessment will be based on the … legislation, which states that tax preparers who prepare more than 10 returns must file them electronically. ... These restrictions will be considered during assessment. … Similarly, please consider the due diligence issue where a tax professional has been engaged to prepare a return for a person for whom no one is authorized to sign a T183. ...

. … Although the section 167 election is generally available to a non-registrant … [a]n election may not be necessary if the conditions of paragraph 141.1(1)(b) are met. ...

Cameco Corporation (2019 FCA 67), CRA Webpage-- summary under Paragraph 231.1(1)(a) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1)- Paragraph 231.1(1)(a) CRA can infer and assume where, post-Cameco, taxpayers refuse interviews After noting that it will not seek to appeal Cameco, CRA indicated that this case decided: [T]he Minister … does not have the authority to compel the employees requested by the CRA to attend interviews and answer oral questions under a general audit and inspection rule of the Income Tax Act. …[T]he FCA … also stated that: all taxpayers should fully cooperate with reasonable requests arising in the course of an audit; it remains open to the Minister to make inferences when no answer is given; and the Minister is free to make assumptions and to assess on that basis. ...

. … On the other hand, for [sponsorship packages A, B, and C], although the sponsors receive the use of real property, they also receive a multitude of promotional services as part of the sponsorship package. ... Therefore, the entire package would be deemed not to be a supply because of section 135 …. ...

Where an election is made, if an amount becomes receivable after 2016 as proceeds of disposition upon the satisfaction of a condition that was part of the agreement under which the disposition was made and the amount would otherwise result in a capital gain for the taxpayer, the amount would under the proposed amendment instead be taxed as it would have been under the ECP regime, with one-half of the gain included in computing the taxpayer's income from a business for a taxation year and the other half … in the taxpayer's capital dividend account. … The taxpayer would need to file this election no later than the filing-due date for the taxpayer's first taxation year that ends after September 30, 2019. ...

CRA responded As indicated in … 37442 (July 30, 2002) a decision on whether to accept a backdated effective date for a section 211 election falls within the purview of the Domestic Compliance Programs Branch … [which] will only consider the backdating of a section 211 election in exceptional circumstances. ...

. … Furthermore, if the operator meets the definition of “builder,” then the operator is within the deeming rules under subsection 191(3) and will be required to report and remit the GST/HST that is deemed under subsection 191(3) to have been collected by the builder. … Even if the operator is a “builder” that is required under subsection 191(3) to report and remit the tax on the self-supply of the MURC, it may not necessarily be entitled to a rebate under subsection 256.2(3) if the residential unit does not meet the definition of a “qualifying residential unit” or if any of the other conditions under section 256.2 for claiming the rebate are not met. ...

. … 12. Transactions between entities that are branches/divisions of the same provincial/territorial government registrant are not treated as supplies for purposes of the GST/HST. … 13. ...