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Administrative Policy summary
GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 -- summary under Subsection 141.01(4)
GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025-- summary under Subsection 141.01(4) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(4) Application of s. 141.01(4) to crypto mining (which is not a taxable supply because no recipient) where there is a view to sale of the crypto (under " Mining activities in respect of cryptoassets prior to February 5, 2022 " under “ITCs where virtual payment instruments are payable in respect of mining activities”) Subsection 141.01(4) can apply in certain circumstances where acquisitions relate to making taxable supplies for no consideration and it can reasonably be regarded that the supply for no consideration is made for the purpose of facilitating, furthering or promoting an endeavour of any person. ...
Administrative Policy summary
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018 -- summary under Subsection 233.8(3)
Amounts in Cdn$/functional currency Table 1 – Overview of allocation of income, taxes and business activities by jurisdictions For electronic filing, all amounts must be stated in Canadian dollars [except that]... ... The reporting entity discloses in Table 3 – Additional Information that it is reporting in one of the qualifying currencies notwithstanding that no election has been made by the reporting entity pursuant to paragraph 261(3)(b) of the Act. ... Payments received from other CEs that are treated as dividends in the payor’s tax jurisdiction should be excluded. … “Revenues-Related Party” should be read as the aggregate amount of revenues generated from transactions between constituent entities listed in Table 2, for each relevant tax jurisdiction. ...
Administrative Policy summary
Revenu Quebec "Place of Supply" -- summary under Subsection 6(1)
Revenu Quebec "Place of Supply"-- summary under Subsection 6(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(1) The place of supply determines whether the HST or the GST and QST apply....For more information on the application of the GST/HST, refer to GST/HST technical information bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province, published by the Canada Revenue Agency. ...
Administrative Policy summary
9 June 2003 Interpretation 43523 -- summary under Subsection 299(2)
This is reinforced in Coopers & Lybrand Ltd. v Bank of Montreal [1993] G.S.T.C. 36…at paragraph 38: …The assessment itself, does nothing other than provide information to the debtor. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.12 -- summary under Subsection 273(1)
Whether the Court’s decision in Medallion … would apply to another situation would require examination of all the relevant facts and documents. ...
Administrative Policy summary
Underused Housing Tax Notice UHTN2 Calculating the Underused Housing Tax Payable January 2023 -- summary under Taxable Value
Underused Housing Tax Notice UHTN2 Calculating the Underused Housing Tax Payable January 2023-- summary under Taxable Value Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Taxable Value Assessed value should be used if higher than value to which property tax is applied Assessed value established by an authority … A property assessment notice (or similar document) and a property tax bill are generally two separate and distinct documents. ...
Administrative Policy summary
T2107 Election for a Disposition of Shares in a Foreign Affiliate -- summary under Subsection 93(1)
Mail one completed copy of this election (plus attachments), separately from any tax return, to your tax centre by the due date identified in [Reg.] 5902(5) …. ... Surplus calculations must be filed with this election … Late or amended elections Late-filed election – subsection 93(5) – we will accept an election filed within three years after the due date and consider it to have been filed on the due date, provided an estimate of the penalty described in subsection 93(6) is paid at the time of filing the election. Special cases – subsection 93(5.1) – we may accept an election filed after the three-year due date or an amended election. ...
Administrative Policy summary
Bulletin PST 315 Rentals and Leases of Goods September 2021 -- summary under Subsection 26(3)
You provide the right to use goods with the right to use real property and the following criteria are met: the term of the right to use the real property is 7 days or less there is no separate charge for the right to use the goods the total amount your customer pays for the right to use the real property is the same as, or only marginally different from, the total amount your customer would have paid if they had not received the right to use the goods 2. You provide the right to use goods with a non-taxable service and the following criteria are met: the main purpose of the contract with your customer is the non-taxable service and not the right to use the goods there is no separate charge for the right to use the goods and they are included as part of the service the total amount your customer pays for the service is the same as, or only marginally different from, the total amount your customer would have paid if they had not received the right to use the goods ...
Administrative Policy summary
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)" -- summary under Specified Arm's Length Supply
Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"-- summary under Specified Arm's Length Supply Summary Under Tax Topics- Excise Tax Act- Section 217- Specified Arm's Length Supply Example of specified non-arm’s length supply Qualifying consideration- Permitted deduction … For example, a qualifying taxpayer that is a non-resident FI incurred an expense for an insurance premium for property outside Canada used in part in respect of its Canadian branch. ...
Administrative Policy summary
T4068(E) Guide for the Partnership Information Return (T5013 Forms) -- summary under Subsection 96(4)
T4068(E) Guide for the Partnership Information Return (T5013 Forms)-- summary under Subsection 96(4) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(4) Filing deadline for tiered partnerships references the “end” members Chapter 4 – Due dates Annual return The due date for filing an annual return (including distributing the T5013 slips) depends on the type of partners, including end members of a tiered partnership. ...