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SKQB decision

Polyco Window Manufacturing Limited v. The Prudential Assurance Company Limited and Berlinex Polymers Inc., Equibuilt Window Systems Inc., K & K Glass Limited, the Minister of National Revenue, Debonair Industries (1987) Limited, Advance Door Systems Limited, Thompson Plastics Limited, 302602 Alberta Limited, C/O A.B.P. Aluminum Building Products, Western Profiles Limited, Moose Jaw Sash & Door Company (1963) Limited and the Director of Labour Standards, [1994] 2 CTC 399

Indeed, Dunlop, in his text Creditor-Debtor Law in Canada (Toronto: Carswell, 1981), stated at page 428 that: ".. ... Harris & Craske (1915), 8 W.W.R. 514, 22 D.L.R. 694 (Sask. C.A.); Randall v. ... Disbursing funds These claims were proved at the hearing: Berlinex $ 91,210.54 Equibuilt $ 91,128.00 K & K Glass $ 61,457.65 Revenue Canada $ 33,108.27 Debonair $ 24,717.00 Advance Door $ 21,145.26 Thompson Plastics $ 18,729.01 302602 Alberta Ltd. $ 11,748.00 Western Profiles $ 11,038.55 Moose Jaw Sash $ 7,438.00 Labour Standards $ 6,000.00 In summary, the $179,500 shall be disbursed as follows: First, to Revenue Canada $ 33,108.27 Second, to The Director of Labour Standards $ 6,000.00 Third, to Advance Door on its assignment date February 25, 1992 $ 21,145.26 Fourth, to the sheriff, the balance for distribu tion pursuant to the Creditors' Relief Act $119,246.47 Funds otherwise payable to Advance shall remain in Court to the credit of the action between Advance and Polyco, until such time as that defended lawsuit is resolved. ...
Miscellaneous severed letter

12 December 1991 Income Tax Severed Letter 912099A F - Income of Contractors — Purchase of Contracts — IT–92R2

12 December 1991 Income Tax Severed Letter 912099A F- Income of Contractors Purchase of Contracts IT–92R2 Unedited CRA Tags 9(1)     5-912099 Dear Sirs: Re:  Purchase of Contracts We are writing in reply to your letter of July 22, 1991 in which you requested our comments with respect to IT-92R2 entitled `Income of Contractors'. ...

10 October 2024 APFF Financial Strategies & Instruments Roundtable

Miscellaneous correspondence
Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...

16 November 2016 Toronto Centre Canada Revenue Agency & Tax Professionals - International Tax Issues

Miscellaneous correspondence
Specifically, there were three things were identified in that Action plan: the master file, the local file, and everybody’s favourite the country-by-country reporting. ... There are other countries the US in particular that have not signed on to that. ... I think you’re right the OECD and many others have said this is a risk-assessment tool it is not a tool that will identify adjustments. ...

Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar

Miscellaneous correspondence
Email this Content Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar ...

20 November 2017 CTF Annual Conference - Diana Aird (Justice) on Rectification & Rescission

Miscellaneous correspondence
There is nobody from the CRA on the Committee it is just a working group of lawyers. ... Contemporaneous documents are usually going to be the most persuasive evidence you have they are much better than someone’s recollection of whatever the tax plan was, years after the fact. ... We sometimes encounter documents that are worded very vaguely asking us to fix the tax mistake and allowing the taxpayer to draft whole new documents, “whatever is needed.” ...

26 February 2019 Toronto CRA & Tax Professionals - International Tax

Roundtable notes
BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized there may be some big changes coming out of that. ... We do not necessarily see that as the case our penalty regime is based on reasonable efforts. ...
Technical Interpretation - External

23 June 2014 External T.I. 2014-0528271E5 F - Terrain « adjacent » à la résidence principale

Faits En XXXXXXXXXX, vous et votre conjointe avez acheté un terrain en copropriété sur le bord d'une rivière Terrain 1 »). ... D'après les faits, tous les critères sont remplis, sous réserve de la signification de « fonds de terre adjacent ». ... La version anglaise de la Loi traduit l'expression « terrain adjacent » par « immediately contiguous land ». ...
Administrative Policy summary

Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries" -- summary under Scientific Research & Experimental Development

Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Administrative Policy summary

Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries" -- summary under Scientific Research & Experimental Development

Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

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