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Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services") -- summary under Section 16
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23. ("HST Place of Supply Rules – Legal Services")-- summary under Section 16 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 16 A GST/HST-registered Canadian law firm performs legal services, as a single, bundled supply, on behalf of a Canadian lender in a secured financing transaction, where the security for the loan is registered under the Personal Property Security Acts in five Canadian provinces against the borrower's tangible personal property, including inventory. ...
Administrative Policy summary
15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations” -- summary under Subsection 95(8)
15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations”-- summary under Subsection 95(8) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(8) Finance has issued a comfort letter respecting umbrella corporation interests where there is no tax avoidance purpose It is not clear to Finance that the compliance burden on a Canadian investor under the tracking interest rules is unusually onerous compared with other compliance obligations under this part of the Act. ...
Scraped CRA Website
EDN29 – Tobacco Stamping Regime – Excise Stamp Order Process
EDN29 – Tobacco Stamping Regime – Excise Stamp Order Process March 2011 The information in this notice does not replace the law found in the Excise Act, 2001 and its regulations and is provided for your reference and convenience only. ... The stamps are available in the following denominations: Cigarettes – 20 units Cigarettes – 25 units Cigarettes – 200 units Tobacco – 50 grams Tobacco – 100 grams Tobacco – 150 grams Tobacco – 200 grams Tobacco – 250 grams Tobacco – 400 grams Cigars Raw leaf Note: Tobacco sticks will also require the above cigarette stamp denominations. ... In accordance with the publicly awarded contract to design, manufacture and distribute the excise stamp, the firm unit price of the excise stamp is as follows: September 1, 2010 to March 31, 2014 – $0.00592 April 1, 2014 to March 31, 2015 – $0.00622 April 1, 2015 to March 31, 2016 – $0.00641 April 1, 2016 to March 31, 2017 – $0.00660 April 1, 2017 to March 31, 2018 – $0.00680 All technical publications related to the Excise Act, 2001 and regulations are available on the CRA Web site at www.cra.gc.ca/exciseduty, under the title "Excise Act, 2001 – Technical Information". ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Guide – Chapter 5 – Farm losses
Farming Income and the AgriStability and AgriInvest Programs Guide – Chapter 5 – Farm losses On this page… Fully deductible farm losses Restricted farm losses (partly deductible) Non-deductible farm losses Non-capital losses When your farming business expenses are more than your farming business income in a year, you have a net loss. However, before you can calculate your net farm loss for the year, you may have to increase or decrease the loss by certain adjustments explained in Line 9941 – Optional inventory adjustment – current year and Line 9942 – Mandatory inventory adjustment – current year. ... The part of Sharon's net farm loss that she can deduct from her other income in 2024 is either amount A or amount B, whichever is less: $9,200 $2,500 plus 50% × ($9,200 − $2,500) $2,500 plus 50% × $6,700 Therefore, B = ($2,500 + $3,350) = $5,850. ...
GST/HST Interpretation
4 July 2013 GST/HST Interpretation 144290 - [...] the availability of a [...] [GST/HST] new housing rebate
4 July 2013 GST/HST Interpretation 144290- [...] the availability of a [...] ... The Purchase Agreement indicates that Schedule A [...], Schedule B [...] and Schedule C [...] are part of this agreement. ... The statement of adjustments indicates a purchase price of $[...], GST of $[...], as well as a GST rebate of $[...]. ...
Current CRA website
Chapter 20 - 8517 – Transfer – Defined Benefit to Money Purchase
Chapter 20- 8517 – Transfer – Defined Benefit to Money Purchase On this page... 20.1 8517(1) – Prescribed Amount 20.2 8517(2) – Minimum Prescribed Amount 20.3 8517(3), (3.001), (3.01), (3.02) – Underfunded Pension 20.4 8517(3.1) – Benefits Provided with Surplus on Wind-up 20.5 8517(4) – Amounts of Lifetime Retirement Benefits Commuted 20.6 8517(5) – Normalized Pension 20.1 8517(1) – Prescribed Amount The prescribed amount is a maximum that limits the amount that may be transferred to an RRSP, RRIF, or MP provision from a DB provision of an RPP under subsection 147.3(4) of the Act. ... Cross references: Transfer – Defined Benefit to Money Purchase, RRSP or RRIF – 147.3(4) Lump Sum Payments on Termination – 8503(2)(h) Commutation of Benefits – 8503(2)(m) Commutation of LRBs – 8503(7) Newsletter No. 94-2, Technical Questions and Answers 20.2 8517(2) – Minimum Prescribed Amount Subsection 8517(2) of the Regulations allows the greater of the amount determined under subsection 8517(1) and the amount in the member’s net contribution account, as defined in subsection 8503(1), to be transferred on a tax deferred basis. ... Although other methods may be considered to be reasonable, the following is an example of a reasonable method to determine the estimate of the MP offset: MP offset = MP account / Factor MP account = value of the individual's MP account at the time of transfer and Factor = (B x C) / D Where B = applicable present value factor at the time of transfer C = the lump sum value of the individual's total lifetime retirement benefit entitlements before MP offset D = prescribed amount of the individual's total lifetime retirement benefit entitlements before MP offset Other methods will be considered on a case by case basis. 8517(5)(f) Paragraph 8517(5)(f) of the Regulations excludes any additional benefits that might become payable as a consequence of the requirements under the PBSA, or similar law of a province. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Appendices
T2 Corporation – Income Tax Guide – Appendices On this page... Related forms and publications List of federal and provincial or territorial corporate schedules and forms Online services Handling business taxes online Electronic payments For more information What if you need help? ... Non-resident corporation enquiries If you have a question about a non-resident corporation account, go to Businesses – International and non-resident taxes or call: Within Canada and continental United States 1-800-959-5525 Monday to Friday (except holidays) 9 a.m. to 6 p.m. ... Mailing address You may write to: International and Ottawa Tax Services Office Post Office Box 9769, Station T Ottawa ON K1G 3Y4 CANADA Fax 613-952-3845 Index Active business income – Schedule 7 Amalgamated corporations Final tax year before amalgamation First tax year – Schedule 24 Appeals Associated corporations – Schedules 23 and 49 Authorizing representatives and employees Available-for-use rule Balance-due day Bar Code (2D) Base amount of Part I tax Books and records Business limit – Schedule 23 Business number Canadian film or video production tax credit – Form T1131 Capital cost allowance (CCA) – Schedule 8 Capital gains refund (federal and provincial or territorial) – Schedule 18 CCA rates and classes Charitable donations – Schedule 2 Control Acquisition of Definition Losses and changes in control Credit unions Additional deduction Allocation in proportion to borrowing – Schedule 17 Cumulative eligible capital deduction – Schedule 10 Deferred income plans – Schedule 15 Direct deposit – Form RC366 Dispositions of capital property – Schedule 6 Dividends – Schedule 3 Paid Received Refund Subject to Part IV tax Earned depletion base – Schedule 12 Election not to be associated – Schedule 28 Eligible dividend General Rate Income Pool (GRIP) Low Rate Income Pool (LRIP) Election to not be a CCPC Excessive dividend designations Exemption from tax under section 149 Federal qualifying environmental trust tax credit Federal qualifying environmental trust tax credit refund Federal tax abatement Filing requirements Acceptable formats Filing deadlines Where to file Who has to file Film or video production services tax credit refund Final return (dissolution) Foreign Affiliates (investment in) – Form T1134, Schedule 25 Business income tax credit – Schedule 21 Non-business income tax credit – Schedule 21 Property Tax deductions, addition to taxable income Functional currency General Index of Financial Information (GIFI) Gifts, Ecological – Schedule 2 Gifts of cultural property – Schedule 2 Gifts of medicine – Schedule 2 Inactive corporations Income exempt under paragraph 149(1)(t) Instalment due dates Instalment payments Internet business activities – Schedule 88 International Financial Reporting Standards (IFRS) Investment Corporation deduction Income – Schedule 7 Tax credit – Schedule 31 Tax credit recapture Tax credit refund Logging tax credit – Schedule 21 Losses Allowable business investment And changes in control Carry-back – Schedule 4 Continuity and application – Schedule 4 Farm Limited partnership Listed personal property Net capital Non-capital Restricted farm Mandatory Internet filing Mandatory electronic filing for tax preparers Manufacturing and processing profits deduction – Schedule 27 NAICS codes Net income (or loss) for income tax purposes – Schedule 1 New corporations – Schedule 24 Non-profit organizations Exempt from tax Information return – Form T1044 Non-resident Corporations Discretionary trust – Schedule 22 Non-arm's length transactions with non-resident persons – Form T106 Ownership – Schedule 19 Payments to – Schedule 29 Online services Part I tax Part II surtax – Schedule 46 Part III.1 Tax – Schedule 55 Part IV tax – Schedule 3 Part IV.1 tax – Schedule 43 Part VI tax – Schedules 38, 39, 42 Part VI.1 tax – Schedules 43, 45 Part XIII.1 tax – Schedule 92 Part VI.1 tax deduction Part XIV tax – Schedule 20 Partnerships Information slip T5013 Elimination of deferral of corporation income tax Patronage dividend deduction – Schedule 16 Payments to non-residents – Schedule 29 Payments to residents – Schedule 14 Penalties Permanent establishment Personal services business Provincial and territorial tax and credits British Columbia Manitoba New Brunswick Newfoundland and Labrador Northwest Territories Nova Scotia Nunavut Ontario Prince Edward Island Saskatchewan Yukon Provincial or territorial Dual income tax rates Foreign tax credits Jurisdiction Tax credits and rebates Tax payable – Schedule 5 Reassessments Reduced business limit Refundable dividend tax on hand Refundable portion of Part I tax Related corporations – Schedule 9 Reserves Capital gains Continuity – Schedule 13 Scientific research and experimental development expenditures – Form T661 Shareholder information – Schedule 50 Short return (T2) Small business deduction Specified investment business Specified partnership income or loss Tax rate (basic) Tax reduction General Tax shelter loss or deduction – Form T5004 Tax withheld at source Taxable income Addition for foreign tax deductions Calculation Used to calculate small business deduction Transactions Non-arm's length – Schedule 44 With shareholders, officers, or employees – Schedule 11 Wind-up of a subsidiary – Schedule 24 Previous page Table of contents Date modified: 2017-01-30 ...
Current CRA website
T2 Corporation – Income Tax Guide – Appendices
T2 Corporation – Income Tax Guide – Appendices On this page... Related forms and publications List of federal and provincial or territorial corporate schedules and forms Online services Handling business taxes online Electronic payments For more information What if you need help? ... Non-resident corporation enquiries If you have a question about a non-resident corporation account, go to Businesses – International and non-resident taxes or call: Within Canada and continental United States 1-800-959-5525 Monday to Friday (except holidays) 9 a.m. to 6 p.m. ... Mailing address You may write to: International and Ottawa Tax Services Office Post Office Box 9769, Station T Ottawa ON K1G 3Y4 CANADA Fax 613-952-3845 Index Active business income – Schedule 7 Amalgamated corporations Final tax year before amalgamation First tax year – Schedule 24 Appeals Associated corporations – Schedules 23 and 49 Authorizing representatives and employees Available-for-use rule Balance-due day Bar Code (2D) Base amount of Part I tax Books and records Business limit – Schedule 23 Business number Canadian film or video production tax credit – Form T1131 Capital cost allowance (CCA) – Schedule 8 Capital gains refund (federal and provincial or territorial) – Schedule 18 CCA rates and classes Charitable donations – Schedule 2 Control Acquisition of Definition Losses and changes in control Credit unions Additional deduction Allocation in proportion to borrowing – Schedule 17 Cumulative eligible capital deduction – Schedule 10 Deferred income plans – Schedule 15 Direct deposit – Form RC366 Dispositions of capital property – Schedule 6 Dividends – Schedule 3 Paid Received Refund Subject to Part IV tax Earned depletion base – Schedule 12 Election not to be associated – Schedule 28 Eligible dividend General Rate Income Pool (GRIP) Low Rate Income Pool (LRIP) Election to not be a CCPC Excessive dividend designations Exemption from tax under section 149 Federal qualifying environmental trust tax credit Federal qualifying environmental trust tax credit refund Federal tax abatement Filing requirements Acceptable formats Filing deadlines Where to file Who has to file Film or video production services tax credit refund Final return (dissolution) Foreign Affiliates (investment in) – Form T1134, Schedule 25 Business income tax credit – Schedule 21 Non-business income tax credit – Schedule 21 Property Tax deductions, addition to taxable income Functional currency General Index of Financial Information (GIFI) Gifts, Ecological – Schedule 2 Gifts of cultural property – Schedule 2 Gifts of medicine – Schedule 2 Inactive corporations Income exempt under paragraph 149(1)(t) Instalment due dates Instalment payments Internet business activities – Schedule 88 International Financial Reporting Standards (IFRS) Investment Corporation deduction Income – Schedule 7 Tax credit – Schedule 31 Tax credit recapture Tax credit refund Logging tax credit – Schedule 21 Losses Allowable business investment And changes in control Carry-back – Schedule 4 Continuity and application – Schedule 4 Farm Limited partnership Listed personal property Net capital Non-capital Restricted farm Mandatory Internet filing Mandatory electronic filing for tax preparers Manufacturing and processing profits deduction – Schedule 27 NAICS codes Net income (or loss) for income tax purposes – Schedule 1 New corporations – Schedule 24 Non-profit organizations Exempt from tax Information return – Form T1044 Non-resident Corporations Discretionary trust – Schedule 22 Non-arm's length transactions with non-resident persons – Form T106 Ownership – Schedule 19 Payments to – Schedule 29 Online services Part I tax Part II surtax – Schedule 46 Part III.1 Tax – Schedule 55 Part IV tax – Schedule 3 Part IV.1 tax – Schedule 43 Part VI tax – Schedules 38, 39, 42 Part VI.1 tax – Schedules 43, 45 Part XIII.1 tax – Schedule 92 Part VI.1 tax deduction Part XIV tax – Schedule 20 Partnerships Information slip T5013 Elimination of deferral of corporation income tax Patronage dividend deduction – Schedule 16 Payments to non-residents – Schedule 29 Payments to residents – Schedule 14 Penalties Permanent establishment Personal services business Provincial and territorial tax and credits British Columbia Manitoba New Brunswick Newfoundland and Labrador Northwest Territories Nova Scotia Nunavut Ontario Prince Edward Island Saskatchewan Yukon Provincial or territorial Dual income tax rates Foreign tax credits Jurisdiction Tax credits and rebates Tax payable – Schedule 5 Reassessments Reduced business limit Refundable dividend tax on hand Refundable portion of Part I tax Related corporations – Schedule 9 Reserves Capital gains Continuity – Schedule 13 Scientific research and experimental development expenditures – Form T661 Shareholder information – Schedule 50 Short return (T2) Small business deduction Specified investment business Specified partnership income or loss Tax rate (basic) Tax reduction General Tax shelter loss or deduction – Form T5004 Tax withheld at source Taxable income Addition for foreign tax deductions Calculation Used to calculate small business deduction Transactions Non-arm's length – Schedule 44 With shareholders, officers, or employees – Schedule 11 Wind-up of a subsidiary – Schedule 24 Previous page Table of contents Report a problem or mistake on this page Privacy statement The information you provide through this survey is collected under the authority of the Department of Employment and Social Development Act (DESDA) for the purpose of measuring the performance of Canada.ca and continually improving the website. ...
Commentary
Rectification & Rescission - Commentary
An attempt by the parties themselves to rectify their transactions on a nunc pro tunc basis may not be respected as having retroactive effect for tax purposes (see S & D), although the parties' self-help rectification in AES (replacing most of a promissory note with preferred shares) was effectively ratified after the fact in a Quebec context. ... However, in S & D, transactions were rectified so as to minimize adverse tax consequences to the extent consistent with the commercial intent of the parties, even though there had not been a continuing intention of the parties to avoid tax. ...
QCQB decision
The North British & Mercantile Fire & Life Insurance Co. v. Lambe, Es-Qualite, [1917-27] CTC 19
The North British & Mercantile Fire & Life Insurance Co. v. Lambe, Es-Qualite, [1917-27] CTC 19 Dorion, C.J. ... Duke of Newcastle & Morris, L.R., 14 H.L. 662; Fryer & Morland, L.R., 3 Ch. ... Jacques & Belisle, and Cushing & Dupuy, 5 H.L. & P.C. 136; 26 L.C.J. 170; 5 Leg. ...