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Miscellaneous severed letter

3 March 1992 Income Tax Severed Letter 9204185 - Pension splitting marriage breakdown — source deductions

3 March 1992 Income Tax Severed Letter 9204185- Pension splitting marriage breakdown source deductions Unedited CRA Tags 56(1)(a)(i), 153(1), 60(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter

10 January 1992 Income Tax Severed Letter 91220187 - Prescribed share — removal of attributes

10 January 1992 Income Tax Severed Letter 91220187- Prescribed share removal of attributes Unedited CRA Tags Reg. 6205(4)(e) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter

25 September 1996 Income Tax Severed Letter 9621415 - GST and QST — home purchase

25 September 1996 Income Tax Severed Letter 9621415- GST and QST home purchase Unedited CRA Tags 62(3)(f) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Lump sum payments out of a registered retirement savings plan — withholding tax

7 October 1991 Income Tax Severed Letter- Lump sum payments out of a registered retirement savings plan withholding tax Unedited CRA Tags 146(1)(a)(i), 153(1)(j), Reg. 103(4), 103(6) Dear Sirs: Re: Lump Sum Payments Out of a Registered Retirement Savings Plan ("RRSP")- Withholding Tax We are writing in reply to your letter of June 7, 1991, in which you ask whether paragraph 153(1)(j) of the Income Tax Act (the "Act") requires a person to withhold tax from lump sum payments out of or under an RRSP and query the accuracy of comments in Information Circular 72-22R8. ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Forgiven interest — timing of the application of paragraph 80(1)(b) and subsection 20(16)

7 October 1991 Income Tax Severed Letter- Forgiven interest timing of the application of paragraph 80(1)(b) and subsection 20(16) Unedited CRA Tags 80(1)(b), 20(16) Subject: Forgiven Interest This is in reply to your memorandum of August 28, 1991 concerning the timing of the application of paragraph 80(1)(b) and subsection 20(16) of the Income Tax (the "Act"). ...
Miscellaneous severed letter

7 November 1991 Income Tax Severed Letter - Transfer of property — timing of income

7 November 1991 Income Tax Severed Letter- Transfer of property timing of income Unedited CRA Tags none TRANSFER OF PROPERTY- TIMING OF INCOME QUESTION A taxpayer purchases the assets of a business from an arm's-length vendor and the completion of the transaction is subject to a condition precedent. ...
Miscellaneous severed letter

11 June 1992 Income Tax Severed Letter - Debtor's gain on settlement of debt — farmers

11 June 1992 Income Tax Severed Letter- Debtor's gain on settlement of debt farmers Unedited CRA Tags 80(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Associated corporations — meaning of “permanent disabilityr” in subsection 256(1.4)

7 October 1991 Income Tax Severed Letter- Associated corporations meaning of “permanent disabilityr” in subsection 256(1.4) Unedited CRA Tags 256(1.4) Associated Corporations Subsection 256(1.4) of the Act expands the scope of association where the parties are given particular options or rights. ...
Miscellaneous severed letter

8 December 1983 Income Tax Severed Letter RRRR86 - Foreign affiliate project LA 5601-C3 — interest income

8 December 1983 Income Tax Severed Letter RRRR86- Foreign affiliate project LA 5601-C3 interest income Unedited CRA Tags 95(2)(a)(i) We have reconsidered our position, at your request, that was stated in our memorandum of April 11, 1983 to you concerning whether the interest income of XXX pertains or is incident to the active business of a related foreign affiliate and is thereby deemed under the provisions of subparagraph 95(2)(a)(i) of the Act to be active business income. ...
Miscellaneous severed letter

7 October 1991 Income Tax Severed Letter - Conversion of preferred shares — subsection 15(1) benefit

7 October 1991 Income Tax Severed Letter- Conversion of preferred shares subsection 15(1) benefit Unedited CRA Tags 15(1) PRINCIPAL ISSUE SHEET- QUESTION PAGE 27 FOR THE 1991 CANADIAN TAX FOUNDATION ROUND TABLE Issue In responding to this query it was assumed that at the time the preferred shares were issued, the holder had the option of converting them into common shares at a preset ratio, or they could be redeemed for a preset amount of cash. ...

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