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Miscellaneous severed letter

3 February 1988 Income Tax Severed Letter 5-5161 - [Payments out of United Nations Joint Staff Pension Fund]

As such, by virtue of the definition of "employee benefit plan" in subsection 248(1) of the Act ("... does not include (a) a fund or plan referred to in subparagraph 6(1)(a)(i)... ...
Miscellaneous severed letter

30 July 1990 Income Tax Severed Letter ACC9607 - Exercise of Exchange Right in Exchangeable Debenture

30 July 1990 Income Tax Severed Letter ACC9607- Exercise of Exchange Right in Exchangeable Debenture 90063-3 Leasing & Financing T. ...
Miscellaneous severed letter

18 January 1990 Income Tax Severed Letter 5-9035 - [Medical Expenses - Paragraph 118.2(2)(c) of the Income Tax Act (the "Act")]

Fisher states "... the basic intention of Parliament must have been to permit a deduction where an individual... necessarily required the services of a full-time attendant by reason of the illness, infirmity or affliction of such individual". ...
Miscellaneous severed letter

10 November 1989 Income Tax Severed Letter AC74133 - Investment Tax Credit - Qualified Transportation Equipment

According to the Canadian Almanac & Directory 1988 Clark Pitman Ltd 24(1) is, not an urban municipality and as a result licenses would be required under the TTA for any transportation service being run out of the community. ...
Miscellaneous severed letter

21 April 1981 Income Tax Severed Letter 7-1171 - [Volume Rebates and Cash Discounts by the Grocery Industry]

Original signed by Chief Merchandising, Manufacturing & Construction Corporate Rulings Division Corporate Rulings Directorate Legislation Branch s.10 Research File CR2220 Inventory ...
Miscellaneous severed letter

4 July 1989 Income Tax Severed Letter AC58088 - Qualified Small Business Corporation Shares

In addition, Holdco contributed a $400,000 loan to the partnership at prime + 1% to be repaid over five years by blended payments of principal and interest. ...
Miscellaneous severed letter

26 September 1989 Income Tax Severed Letter AC58302 - Barter Arrangement

London & West Riding Investments Ltd. (1967) 1 All E.R. 518 (CA) and cited with approval by then Supreme Court Chief Justice Estey in Stubart Investments Ltd. v. ...
Miscellaneous severed letter

12 January 1990 Income Tax Severed Letter 7-4437 - [Stock Option, Stock Option Deduction and Capital Gains Deduction]

May 4, 1988 FMV of Block 1 $170,000.00 Less: ACB 1.00 Benefit $169,999.00 November 1988 FMV of Block 2 $350,000.00 Less: ACB 250 000 00 Benefit $100.000.00----------- Total Stock Option Benefit $269,999.00 =========== CAPITAL GAIN CALCULATION Proceeds- Block 1 $380,000.00 Block 2 350.000.00 $730,000.00 Less:ACB Block 1 1.00 Block 2 250,000.00 Stock Option Benefit 269.999.00 520.000.00 Total Capital Gain $210,000.00 Taxable Capital Gain- 2/3 $140,000.00 The taxpayer's accountant is of the view that his client is entitled to the stock option deduction pursuant to paragraph 110(1)(d.1) of the Act and the capital gains deduction in respect of qualified small business corporation shares pursuant to subsection 110.6(2.1) of the Act on the sale of the Block 1 shares in November of 1988. ...
Miscellaneous severed letter

31 October 1989 Income Tax Severed Letter AC58952 - CCA Class on Telecopier (Fax) Machines

Toussaint Director Bilingual Services & Resource Industries Division Rulings Directorate ...
Miscellaneous severed letter

15 May 1986 Income Tax Severed Letter 5-0458 - [*Child Care Expenses]

In our view, the case of Olympia Floor & Wall Tile (Quebec) Ltd. v. ...

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