Search - 报销 发票日期 消费日期不一致

26 September 1989 Income Tax Severed Letter ACC8685 F- Certificate of Coverage under Canada-Germany Social Security Agreement Unedited CRA Tags n/a     IX 3 A(1) F-191.221.1(509) 19(1) A. Watson    (613) 957-2072   HBW 4131-G1 September 26, 1989 RE: APPLICATION OF ARTICLE 10 IN THE CASE OF 19(1) This is in answer to your letter dated June 28, 1989, in which you request our concurrence in special arrangements under Article 10 of the Social Security Agreement between Canada and the Federal Republic of Germany. ... SavageActing DirectorProvincial and InternationalRelations Division c.c.      ...

12 October 1989 Income Tax Severed Letter ACC8587 F- Canada-France Tax Convention Unedited CRA Tags n/a   October 12, 1989 S. Kotler Provincial and International Director Relations Division Registered Pensions and Legislative & Intergovernmental Deferred Income Plans Affairs Branch   Al Watson Attention: N. Pettifer 957-2072      HBW 4125-F1 24(1) PARAGRAPH 5, ARTICLE XXIX CANADA-FRANCE INCOME TAX CONVENTION As competent authority, we have been asked to agree that the pension plans referred to in the attached submission correspond to pension plans which would be recognized for income tax purposes in Canada. ...

Wheeler for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch c.c.       ... Adams      Audit Technical Services ...

An example of this tax reduction is as follows: Canadian Employment Income $59,000 Interest Income from Canadian sources $1,100(A) Less: Expenses incurred to earn the Canadian interest income 100 1,000(B) Net Income $60,000 Deductions in computing taxable income 10,000 Taxable Income $50,000(C) Total Federal and Provincial Taxes Payable 40- Rate C X 40%- $50,000 X 40% = $20,000(D) Taxes Payable relating to Canadian Interest Income B/C X D- $ 1,000/$50,000 X $20,000 = $ 400(E) Limitation under paragraph 2 of Article 11 of the Convention 10% X A- 10% X $1,100 = $ 110(F) Tax Reduction E- F $400- $110 = $ 290(G) Note: The tax reduction should be apportioned on a reasonable basis between the Federal and Provincial taxes payable. Revised Taxes Payable D- G $20,000- $290 = $19.710 Please note that this approach produces the correct net income amount which is used for the purposes of calculating various tax credits. ...

., b) for the purposes of Regulation 1100(1)(ta)(i)(A) the Class 29 property was acquired by the partnership in a "specified transaction", and c) the maximum capital cost allowance which the partnership may claim in respect of its 1988 taxation year is computed as follows: 1100(l)(ta) An amount not exceeding the aggregate of (i) the aggregate of (A) the lesser of (I) 50% of cost of designated property $10,000,000 =========== (II) UCC in respect of designated property $ 8,000,000 $8,000,000 =========== (B) 25% of the lesser of (I) UCC not including designated property $ 2,000,000 =========== (II) capital cost of non designated property acquired in year $ 2,000,000 500,000 =========== $8,000,000---------- (ii) the lesser of (A) UCC less cost of property acquired in year $NIL ==== (B) an amount equal to the aggregate of (I) 50% of property acquired in the preceding year $NIL (II) excess of clause (A) over certain amounts NIL $NIL- ====__________ Available CCA $8,500,000 ========== The existing rules, which apply to exempt property acquired on a rollover basis from the application of the half-year capital cost allowance convention are expected to change under the proposed White Paper of June 18, 1987, if passed in its present form. ...

14 June 1989 Income Tax Severed Letter 89M06083 F- Business Meeting Expenses Unedited CRA Tags n/a   June 14, 1989 CGA ASSOCIATION ROUND TABLE QUESTION A recent article in the CGA Magazine discussed the contentious issue of business meeting expenses and highlighted a case relating to the deductibility of in-country and out-of-country expenses.  ... DEPARTMENT'S POSITION A distinction must be made between: (1)      expenses of attending business meetings and (2)      expenses incurred in attending conventions. ...

5 October 1989 Income Tax Severed Letter ACC8590 F- Interest Paid to Bank in Korea Exempt from Non-resident Withholding Tax Unedited CRA Tags n/a 19(1) HBW 9412-2-3   HBW 4125-K3   Jim Wilson   (613) 957-2063 October 5, 1989 19(1) We are writing in reply to your letter dated August 11, 1989, concerning the above-noted organization. ...

14 September 1989 Income Tax Severed Letter ACC8577 F- Form 96 for Relief of Swiss Withholding Tax Unedited CRA Tags n/a 19(1) HBW 6591-S4   HBW 6591-4   E.E. Campbell   (613) 957-2067 September 14, 1989 Re:  (Form 96) for relief of Swiss withholding tax Recently you sent us one book each of the French and English version of form 96.  ...

Z avance 225 000 $ à la corporation B contrôlée par M. T, le frère de M. 1. 2) La corporation A a hypothéqué ses biens afin de pouvoir prêter sans intérêt à la corporation B. 3) L'année suivant l'avance, la corporation B a fait faillite et la corporation A a réclamé une perte en capital de 225 000 $ et elle réclame toujours les intérêts sur l'hypothèque. ... Lemelin Chef Section des applications de la vérification CD 1640-20(l)(c) & 39(1)(b) & (c) & 40(2)(g)(ii) ...

Since that article does not define the term "gain" for purposes of the Convention, it is necessary to follow the provisions of paragraph 2 of Article III which states that "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of that State concerning taxes to which the Convention applies". ... We trust this is adequate for your purposes. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch APPENDIX A Proceeds (April 30, 1989) $150,000 Cost $ 50,000 V-Day Value $ 80,000 Outlays and Expenses $ 10,000 # of months property owned after December 31, 1971 208 # of months property owned between December 31, 1971 and December 31, 1984 156 Proceeds of disposition $150,000 Less: ACB $80,000 Outlays and Expenses $10,000 90,000 Gain liable to tax $ 60,000 Taxable Capital Gain (115(1)(b)) $60,000 X 2/3 $ 40,000 Exempt Portion of Gain (Article XIII(9)) $60,000 X 156/208 $ 45,000 Deduction from Income (115(1)(d) and 110(1)(f)) $45,000 X 2/3 $ 30,000 ...