Search - 江苏苏美达轻纺国际贸易有限公司 关税政策 最新动态

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 23-- summary under Subsection 173(1) Summary Under Tax Topics- Excise Tax Act- Section 173- Subsection 173(1) no ITC on taxable resale of personal property where ITC was denied under s. 170 A registrant acquires personal property strictly for the personal use, free of charge, of an employee or a shareholder. Under s. 170, the registrant may not claim an input tax credit for the GST/HST paid on the purchase, and under s. 173(1)(c) the use of the registrant in so supplying the property to the employee/shareholder is deemed to be use of the property goods in the course of a commercial activity – so that a resale of the goods is taxable under s. 200 or 141.1. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 21-- summary under Section 284.01 Summary Under Tax Topics- Excise Tax Act- Section 284.01 reporting RITC for wrong province results in penalty Will CRA assess penalties under s. 284.01 where a large business inadvertently reports the wrong province to which a recaptured input tax credit relates (e.g., Ontario rather than B.C.), but this error does not result in an increase to the net input tax credits that should be reported? ... As the penalty calculations in section 7 of the Regulations are based on the difference between the RITCs that should have been reported for each particular province in a specified return for a reporting period and the RITCs that were actually reported, or un-reported, for that particular province in that return, the over-reported amount of RITCs for Ontario would result in a negative penalty calculation… that…[p]ursuant to section 125… is deemed to be nil. … However, the un-reported amount of RITCs for British Columbia would result in a penalty amount equal to a minimum of 5%, to a maximum of 10%, of that un-reported amount, where the amount remains unreported for 5 complete months or more. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35-- summary under Section 28 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 28 fee for training session or seminar was for IPP Conference example ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present papers and lead workshops at the conference. ... The place of supply rules in sections 6 and 7…would generally be relevant…. … Generally, to determine that a particular supply is a service, it would have to be established based on a complete set of facts that the predominant element of the supply is a service…. ...

GST/HST Memorandum 4.5.2 (4-5-2) "Exports – Tangible Personal Property" August 2014-- summary under Subsection 153(6) Summary Under Tax Topics- Excise Tax Act- Section 153- Subsection 153(6) 58. ... This sometimes involves transactions whereby the person holding the rights to the natural gas liquids exchanges the liquids or the rights to them for the make-up gas supplied by the other party to the transaction. … 59. ...

3 February 2016 Interpretation 159181 Supplies made by […][a Municipality] to the […] First Nation-- summary under Paragraph 12(a) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 12- Paragraph 12(a) overlap with Indian Act exemption After noting that band management activities (“BEE”) are those activities conducted by bands and band-empowered entities (as defined in B-039) (“BEEs”) “with regard to their normal administration, programs, services and activities that are designed and/or are delivered for the well-being or assistance of band members and are generally similar to those provided by other levels of government,” CRA stated: …[S]ervices acquired on or off a reserve by the First Nation for …band management activities (“BMA”)] or for real property on a reserve are not subject to the GST/HST. ... However, … section 12 of Part VI of Schedule V to the ETA… exempts the supply made by a public sector body, such as a municipality, of a membership in, or services supplied as part of a program that is established and operated by the body and that consists of a series of supervised, instructional classes or activities in athletics, outdoor recreation, music, dance, arts, crafts or other recreational pursuits where the nature of the activities, or the level of skill required, is such that the program can reasonably be expected to be provided primarily to children 14 years of age or under. ...

IC 77-16R4 – Non-Resident Income Tax, 11 May 11 1992-- summary under Subsection 212(2) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(2) Exemption on portfolio dividends paid to a foreign government Sovereign Immunity 50. ... The written authorization will have an expiry date at which time the Canadian payer would be required to re-apply for further authorization not to withhold. … Investment income of a foreign government or its agency is exempt only if (a) the other country would provide a reciprocal exemption to the Canadian Government or its agencies; (b) the income is derived by the foreign government or agency in the course of exercising a function of a governmental nature and is not income arising in the course of an industrial or commercial activity carried on by the foreign authority; and (c) it is interest on an arm's length debt or portfolio dividends on listed company shares. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.4(3) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(3) Application of NT-2023-05 (re B2B arrangements) to cash pooling arrangements NT-2023-05. ... A filing generally is not required where the Canadian taxpayer participating in the cash pooling arrangement is solely a creditor …. ...

. – Q.37-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) partner carries on loss business through partnership Where a loss corporation transfers its entire business to a partnership of which it is a member, would it for the purposes of s. 111(5), as partner, be considered to carry on "that business" carried on by the partnership, and would the income of a partner from a partnership be considered to be from a "similar business," for the purposes of ss. 111(5)(a)(ii) and (b)(ii), if the business of the partnership satisfied the criteria set out therein in relation to a business carried on directly by the partner? ... However, the addition of other assets upon the introduction of other partners may result in a different business being carried on by the partnership. … [T]he income of a partner from a partnership would be considered to be income from a "similar business" if the business carried on by the partnership satisfied the criteria set out in subparagraphs 111(5)(a)(ii) and (b)(ii) in relation to a business carried on directly by the partner. ...

– Limitations on Expenditures Pursuant to Sections 143.3 and 143.4," draft version of paper for CTF 2014 Conference Report.-- summary under Right to reduce Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(1)- Right to reduce Does automatic adjustment entail "exercise"? ... While the authors understand, based on informal discussions with the Department of Finance, that automatic adjustments are intended to be captured, the use of the adjective "exercisable", together with the phrase "an amount to the extent that the taxpayer [...] has a right to reduce the amount", provides support for the conclusion that an dement of discretion on the part of the taxpayer is required…. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 20. ... In confirming that the s. 167 election would not be available for the business acquisition by Newco if Newco did not carry on a business before its amalgamation, CRA stated: Under section 271, an Amalco is deemed for GST/HST purposes to be a separate person from each of its predecessors, except as otherwise provided under the ETA. … There is no provision deeming a predecessor (in this case, Newco) to acquire the characteristics of its successor Amalco. ...