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Article Summary
David M. Sherman, "GST Tidbits – Backdating of Voluntary Registrations by 30 Days", GST & HST Times, Release No. 280C – March 2013 -- summary under Subsection 240(1)
Sherman, "GST Tidbits – Backdating of Voluntary Registrations by 30 Days", GST & HST Times, Release No. 280C – March 2013-- summary under Subsection 240(1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1) At CRA's annual GST/HST meeting with the Canadian Bar Association Commodity Tax section on February 23, 2012, CRA stated in Question 48: For a voluntary GST/HST registration the CRA will accept an effective date of registration that is within 30 days of the date when the registration was made, regardless of the method of registration (online, telephone, or paper). ...
Article Summary
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II) -- summary under Paragraph 84.1(2)(e)
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) Overview Bill C-208 generally provides that an individual selling qualified small business shares or shares of a family farm or fishing corporation to a corporation controlled by the individual’s children or grandchildren who are at least 18 years of age will benefit from capital gains treatment rather than a s. 84.1 deemed dividend provided that such purchaser does not dispose of those shares for at least 60 months. ... Example of strip Emily transfers her shares of a small business corporation (Petco) with nominal tax basis and paid-up capital to a Newco- in which her daughter owns nominal value special voting shares giving her voting control, and Emily owns the balance of the equity – in consideration for a promissory note, which is repaid over the next five years with intercorporate dividends received by Newco from Petco. ... Furthermore, the math in the formula is wrong – even if it were effective, it would only eliminate the deduction at taxable capital levels of $510 million, not $15 million. ...
GST/HST Interpretation
15 May 2014 GST/HST Interpretation 155042 - – […] [FCTIP – Foreign Convention]
Individual participants chose […] for the […] portion of [the Event]. […]. 15. […] 16. The schedule for [the Event] […] [was] as follows: […] 17. [The Event] was officially opened […]. ... The […] portion of [the Event] provided participants with the opportunity to […] while discovering […][a Canadian City] through […] activities. […]. 24. […] 25. ...
Current CRA website
Chapter 15 - 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan
Chapter 15- 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan On this page... 15 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan 15.1 8507(1) – Prescribed Compensation 15.2 8507(2) – Additional Compensation in Respect of Qualifying Period 15.3 8507(3) – Qualifying Periods and Periods of Parenting 15.3.1 8507(3)(a) – Qualifying period 15.3.2 8507(3)(b) – Period of parenting 15.4 8507(4) – Cumulative Additional Compensation Fraction 15.5 8507(5) – Additional Compensation Fraction 15.6 8507(6) – Exclusion of Subperiods 15.7 8507(7) – Complete Period of Reduced Pay 15.8 8508 – Salary Deferral Leave Plan 15 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan Section 8507 of the Regulations contains rules that enable DB benefits to be provided, or MP contributions to be made, in respect of a period of disability, a leave of absence, or a period of reduced pay as if it were a regular period of employment without violating the PA limits in subsections 147.1(8) and (9) of the Act. ... Cross references: Pension Adjustment Limits – 147.1(8) Pension Adjustment Limits – Multi-Employer Plans – 147.1(9) Period of Reduced Services – Retroactive Benefits – 8308(4) Period of Reduced Services – Retroactive Contributions – 8308(5) Definition of Eligible Periods of Reduced Pay – 8500(1) Definition of Eligible Periods of Temporary Absence – 8500(1) Definition of Periods of Disability – 8500(1) Additional Compensation in Respect of Qualifying Period – 8507(2) Qualifying Periods – 8507(3) 15.2 8507(2) – Additional Compensation in Respect of Qualifying Period This subsection contains the rules for determining the amount that is prescribed by subsection 8507(1) of the Regulations in respect of a qualifying period of a member in a year with respect to an employer. ... Cross references: Definition of Eligible Periods of Reduced Pay – 8500(1) Definition of Eligible Periods of Temporary Absence – 8500(1) Deemed Allocation of Forfeitures and Surplus – 8500(7) Definition of SMEP – 8510(2) 15.3.2 8507(3)(b) – Period of parenting This is all or part of the period that starts at the time of the birth or adoption of a child and ends 12 months later. ...
SCC
Town of Beauport v. Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. Town of Beauport, [1945] SCR 16
Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. ... Upon the declaration being made that the works of the Company were for the general advantage of Canada, the effect of subsection 10 of s. 92 of The British North America Act is * * * to transfer the * * * works mentioned * * * into s. 91 and thus to place them under the exclusive jurisdiction and control of the Dominion Parliament. ...
Current CRA website
Chapter 19 - 8515 & 8516 – Special Rules for Designated Plans & Eligible Contributions
Chapter 19- 8515 & 8516 – Special Rules for Designated Plans & Eligible Contributions On this page... 19.1 8515(1) – Designated Plan 19.2 8515(2) – Designated Plan in Previous Year 19.3 8515(3) – Exceptions 19.4 8515(3.1) – Exceptions 19.5 8515(4) – Specified Individual 19.6 8515(5) – Eligible Contributions 19.7 8515(6) – Funding Restriction 19.8 8515(7) – Maximum Funding Valuation 19.9 8515(8) – Restricted-Funding Members 19.10 8515(9) – Member Contributions 19.11 8516(1) – Prescribed Contribution 19.12 8516(2) – Funding on Termination Basis 19.13 8516(3) – Contributions Required by Pension Benefits Legislation 19.1 8515(1) – Designated Plan An RPP with a DB provision is a designated plan throughout a year if the pension credits of specified individuals (defined in subsection 8515(4) of the Regulations) exceed 50% of all pension credits for the year under the provision. ... Cross references: Specified Individual – 8515(4) Eligible Contributions – 8515(5) Restricted-Funding Members – 8515(8) Member Contributions – 8515(9) FAQ No. 25 – Ministerial Waivers Under 8515(2) 19.3 8515(3) – Exceptions A plan will not become a designated plan if the following conditions are met: The plan would not be a designated plan in the year if the reference in paragraph 8515(1)(b) of the Regulations to “50%” were read as “60%”; The plan was established before the year; and The plan did not meet the condition under subsection 8515(1) of the Regulations to be a designated plan in the immediately preceding year. ... Cross references: Definition of Designated Plan – 8500(1) Designated Plan in a Previous Year – 8515(2) 19.5 8515(4) – Specified Individual An individual is a specified individual in a calendar year if the individual is connected at any time with a participating employer under the plan or the individual’s total remuneration for the year exceeds 2½ times the YMPE for the year. ...
Administrative Policy summary
GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality -- summary under Subsection 295(5)
GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality-- summary under Subsection 295(5) Summary Under Tax Topics- Excise Tax Act- Section 295- Subsection 295(5) Informal request in lieu of ATIP request When an access to information and privacy (ATIP) request is received, the Access to Information and Privacy Directorate of the Public Affairs Branch forwards the request to the appropriate party(ies) to obtain the relevant information. ... Permitted scope of informal request Some examples of information that can be released to a registrant or authorized representative under an informal request include: • the T20 Report • external and internal correspondence, including memoranda, appropriately severed where necessary • related correspondence with Headquarters such as technical interpretation requests or opinions and referrals to specialized sections about a specific person • working papers, excluding third-party information, leads, disclosure of audit techniques, and information from informants • related reports from external and internal valuators, appraisers and electronic commerce audit specialists, • severed versions of operations manuals available to the public Examine the documents before releasing them to ensure no confidential information about a third party is released. Prohibited disclosures Examples of information that cannot be released are: • information obtained in confidence during an audit or examination that may prejudice the results of the audit or examination, such as Criminal Investigation reports, Royal Canadian Mounted Police reports, or documents obtained as part of an investigation • audit techniques and specific audit guidelines • information about investigations in process when a decision is pending • documents of a related file under investigation • confidential information about another registrant • Department of Justice correspondence and information under solicitor-client privilege, including legal opinions from the Legal Services Branch (for more information, go to Disclosing legal opinions and Use of legal opinions inside the Agency) • specific advice and recommendations developed by or for a government institution or minister of the Crown that may restrict the CRA's ability to administer the ETA if they are disclosed • accounts of consultations and deliberations involving officials or employees of a government institution or a minister of the Crown that may reasonably be expected to cause injury or restrict the CRA's ability to administer the ETA if disclosed • information released to a third party, other than specifically permitted by paragraph 295(5)(d) of the ETA or where consent is given by the registrant • copyright material • computer printouts from CRA computer systems. ...
Administrative Policy summary
SR & ED 95-02R "Science Eligibility Guidelines for the Oil & Gas of Mining Industries" -- summary under Scientific Research & Experimental Development
SR & ED 95-02R "Science Eligibility Guidelines for the Oil & Gas of Mining Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Current CRA website
Chapter 6 - 8303, 8308 & 8409 – Pension Adjustments & Annual Information Returns
Chapter 6- 8303, 8308 & 8409 – Pension Adjustments & Annual Information Returns 6.1 8303(6) – Qualifying Transfers 6.2 8303(7) – Deemed Payment 6.3 8303(10) – Benefits in Respect of Foreign Service 6.4 8308(7) – Loaned Employees 6.5 8409(1) and (2) – Annual Information Returns 6.1 8303(6) – Qualifying Transfers Subsection 8303(6) of the Regulations defines for the purposes of the description of C in the formula in subsection 8303(3) (basic PSPA calculation), the description of D in the formula in subsection 8304(5) (modified PSPA calculation) and the description of B in the formula in subsection 8304(10) (IPP PSPA calculation), the amount of an individual’s qualifying transfer made in connection with a past service event. ... Cross reference: Deemed Registration – 147.1(3) 6.3 8303(10) – Benefits in Respect of Foreign Service Subsection 8303(10) of the Regulations allows the CRA to exclude past service benefits provided for a period of foreign service from PSPAs. ... Cross references: Participating Employer – 147.1(1) Pension adjustment limits – 147.1(8), 147.1(9) Eligible Service – 8503(3)(a) Maximum Benefits – 8504(1) Additional Compensation Fraction – 8507(5) 6.5 8409(1) and (2) – Annual Information Returns The plan administrator will have to file either: a joint annual information return by the date prescribed under the pension benefits legislation of a participating provincial pension supervisory authority; or for a non-participating pension supervisory authority a Form T244, Registered Pension Plan Annual Information Return, within 180 days of the plan's year-end. ...