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Administrative Policy summary

23 December 2016 Comfort Letter re s. 95(2)(b) base erosion rule -- summary under Subclause 95(2)(b)(i)(B)(I)

Holdco was formed to acquire shares of Opco, carrying on an active business, and Manager provides asset management and investment advisory services respecting Opco for a fee which is paid by Holdco, rather than Opco, because Holdco is not the sole shareholder of Opco. ...
Administrative Policy summary

23 March 2017 CBA Commodity Taxes Roundtable, Q.20 -- summary under Section 2

. If Mr. X is not a builder in his own right (for example, at the time of entering into the agreement of purchase and sale, he intended to acquire the house for his personal use), the sale of that interest would generally be exempt under section 2 of Part I of Schedule V to the ETA. ...
Administrative Policy summary

2024 Alberta CPA Roundtable, Q.3 -- summary under Subsection 315(3)

Any postponement under this subsection requires approval of the appropriate delegated authority Specific to the postponement of GST/HST amounts owing which have been objected to, where the taxpayer is unable to provide security in a form and amount satisfactory to the Minister, postponement will only be considered where: the registrant remains current with tax compliance requirements for all associated accounts the GST/HST amounts in dispute have not already been collected by the registrant at all times during the objection and/or appeal, the business remains in good financial standing the registrant provides relevant information after an assessment is raised that may result in the assessment being overturned the registrant’s objection and/or appeal identifies reasonable differences in the interpretation of the legislation the registrant has Canadian-based assets The decision to postpone collection action without the acceptance of security is a local business decision made on a case-by-case basis, based on the facts of each specific account. ...
Administrative Policy summary

P-171R "Distinguishing Between a Joint Venture and a Partnership for the Purposes of Section 273 Joint Venture Election" 24 February 1999 -- summary under Subsection 273(1)

The participant's specified interest could be x % of every product produced or 100% of one product and 0% of the other products.... ...
Administrative Policy summary

GST/HST memorandum 9.4 "Reimbursements" June 2012 -- summary under Subsection 175(1)

There is no employer employee relationship between Company A and the employees of Company B. ...
Administrative Policy summary

Bulletin PST 316 "Bundled Sales and Leases" -- summary under Subsection 26(3)

. Example 2 For $15,000 per month, you lease a restaurant building with affixed machinery (beer tap equipment) and various furniture. ...
Administrative Policy summary

2 December 2014 CTF Roundtable, Q. 4 -- summary under Subsection 212.1(4)

Therefore, the application of subsection 212.1(4) in this case would defeat the objective of section 212.1…. ...
Administrative Policy summary

4 September 2003 Ruling 46189 -- summary under Subparagraph 7(a)(ii)

During Period 2, the s. 7(a)(ii) exemption will not apply to the Base Rents nor will s. 6.1, since the Developer has acquired the Residential Units for the purpose of making supplies of the Units by way of assignment. ...
Administrative Policy summary

AD-18-01: "Taxable Benefit for the Personal Use of an Aircraft" 17 March 2018 -- summary under Subsection 15(1)

It is generally less favourable than that in (cancelled) IT-160R3 under which, for example, the benefit could be computed based on the cost of a first-class ticket in a wider range of circumstances (and for a “small, inexpensive aircraft,” might be based on an economy class fare) and there was no mention of an imputed available-for-use benefit based on the aircraft’s cost. ...
Administrative Policy summary

17 May 2017 Interpretation 174642 -- summary under Subsection 191(3)

It is estimated that during the regular academic session from September to May, more than 10% of the units will be supplied for short-term stays (generating rentals of more than $20 per day) and, during June through August, that 90% or more of the apartment units will be supplied for short-term stays (under one month) with the balance for long-term stays. ...

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