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Technical Interpretation - Internal summary

24 April 2012 Internal T.I. 2012-0440711I7 F - Indemnité de repas; remboursement pour déplacement -- summary under Paragraph 6(1)(b)

As a result, the total amount of the allowances, as well as meal vouchers, should be included on the T4 slip in box 14 …. ...
Technical Interpretation - Internal summary

1 March 2012 Internal T.I. 2012-0437901I7 F - Timing of the adjustments pursuant to 111(5) -- summary under Paragraph 111(5)(a)

1 March 2012 Internal T.I. 2012-0437901I7 F- Timing of the adjustments pursuant to 111(5)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) acquisition of control of target does not reduce its NCLs at that time streaming rules apply prospectively A corporation acquired all of the shares of a target corporation, resulting in an acquisition of control, and a day later, they amalgamated to form "Amalco". ...
Technical Interpretation - Internal summary

1 December 2015 Internal T.I. 2015-0588381I7 F - Classification of US-LLCs -- summary under Section 96

. [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...
Technical Interpretation - Internal summary

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment -- summary under Subsection 5(1)

. Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...
Technical Interpretation - Internal summary

28 April 2011 Internal T.I. 2011-0394301I7 F - Obligation de l'employeur - feuillet T4 modifié -- summary under Subsection 152(4.2)

28 April 2011 Internal T.I. 2011-0394301I7 F- Obligation de l'employeur- feuillet T4 modifié-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) procedure for employee to request correction of incorrectly reported T4 benefit When asked what an employer should do when it discovers that T4 slips issued by it incorrectly showed an automobile benefit, CRA stated: [S]ubsection 152(4.2) covers, in particular, situations in which an employee, who has received T4 slips that have been amended for previous taxation years, requests the CRA to correct the income tax return already filed for those taxation years. ...
Technical Interpretation - Internal summary

30 September 2011 Internal T.I. 2011-0393171I7 F - Representation or other special allowances -- summary under Subparagraph 6(1)(b)(iii)

The Directorate first quoted a statement in 2005-0158871E5 that: [A] "representation allowance" in the context of subparagraph 6(1)(b)(iii) is an allowance paid to a worker having to work outside the country and is intended to lessen the inconveniences arising out of having to move abroad, being subject to different living conditions and, where applicable, having to face a higher cost of living. ...
Technical Interpretation - Internal summary

15 December 2011 Internal T.I. 2011-0413891I7 F - Récupération d'amortissement-Recapture CCA -- summary under Income or Loss

It then started leasing the property to a non-associated corporation and then disposed of the property, thereby realizing recapture of depreciation. ...
Technical Interpretation - Internal summary

7 June 2011 Internal T.I. 2011-0397921I7 F - Financement inter-sociétés -- summary under Subsection 15(2.1)

We continue to believe that the term "person connected with a shareholder of a particular corporation" as provided in subsection 15(2.1) may include a partnership. ...
Technical Interpretation - Internal summary

7 June 2011 Internal T.I. 2011-0397921I7 F - Financement inter-sociétés -- summary under Subsection 227(6.1)

In the course of a general discussion, CRA stated: Subsection 227(6.1) provides for repayment of Part XIII tax paid on a loan deemed to be a dividend by virtue of paragraph 214(3)(a) if the borrower, in whose name the tax was paid, repays the loan after December 21, 1992 and the repayment was not made as part of a series of loans or other transactions and repayments. ...
Technical Interpretation - Internal summary

2 September 2011 Internal T.I. 2011-0419111I7 F - Programme de compensation du MESS -- summary under Paragraph 56(1)(u)

2 September 2011 Internal T.I. 2011-0419111I7 F- Programme de compensation du MESS-- summary under Paragraph 56(1)(u) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) social assistance payments aggregating less than $500 not required to be included in income After noting that payments made by Ministère de l'Emploi et de la Solidarité sociale (the "MESS") to individuals, who were homeless and receiving financial assistance of last-resort represented social assistance payments described in s. 56(1)(u), CRA stated: ITR subsection 233(2) provides that a T5007 return does not have to be filed in certain circumstances, including where: the payment is paid as a part of a series of payments, the total of which in the particular year does not exceed $500 …. ...

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