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Conference summary
11 October 2013 Roundtable, 2013-0499671C6 F - Actif d'impôts futurs / Future income tax assets -- summary under Small Business Corporation
11 October 2013 Roundtable, 2013-0499671C6 F- Actif d'impôts futurs / Future income tax assets-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation future income tax asset is not an asset – tax receivable is, but is an active business asset if it arose from active business Is a future income tax asset an asset used in an active business for the purposes of the definition of qualified small business corporation share in s. 110.6(1) and of small business corporation in s. 248(1)? ... The tax receivable may be an asset used in the active carrying on of a business for [such] purposes …. For example … tax receivable due to the carryback of a loss from an active business is an asset used primarily in the business that the corporation is actively carrying on for purposes of both definitions. … The same interpretation applies to deferred tax assets. ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Guide – Chapter 3 – Calculating your farming income or loss
Eligible leasing costs for passenger vehicles Total lease charges incurred in your 2024 fiscal period for the vehicle $ Line 1 Total lease payments deducted before your 2024 fiscal period for the vehicle $ Line 2 Total number of days the vehicle was leased in 2024 and before 2024 Line 3 Manufacturer's list price $ Line 4 The amount on line 4 or ($43,529 Footnote 4 + GST Footnote 5 and PST Footnote 5, or $43,529 Footnote 4 + HST Footnote 5),_____× 85% (whichever is more) = $ Line 5 [($1,050 Footnote 6 + GST Footnote 5 and PST Footnote 5, or $1,050 Footnote 6 + HST Footnote 5)× line 3] ÷ 30]_____ − line 2:_____ = $ Line 6 [($37,000 Footnote 7 + GST Footnote 6 and PST Footnote 5, or $37,000 Footnote 7 + HST Footnote 5) × line 1] ÷ line 5 = $ Line 7 Eligible leasing cost: Line 6 or line 7, whichever is less $ Repayments and imputed interest When you lease a passenger vehicle, you may have a repayment owing to you, or you may have imputed interest. ... For more information on OIA, see Line 9941 – Optional inventory adjustment – current year. ... Therefore, the amount that he enters on line 12 is $14,210 [70% × ($13,300 + $7,000)]. ...
Decision summary
Livent Inc. v. Deloitte & Touche, 128 OR (3d) 225, 2016 ONCA 11, rev'd in part 2017 SCC 63 -- summary under Negligence, Fiduciary Duty and Fault
Deloitte & Touche, 128 OR (3d) 225, 2016 ONCA 11, rev'd in part 2017 SCC 63-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault auditors liable for failure to detect the company’s own fraud effected through its senior management A negligent audit by an auditing firm (“Deloitte”) of a Canadian public corporation (“Livent”), in which Deloitte failed to discover that senior management was fraudulently misstating the financial statements, was found by the trial judge to have resulted in damages to Livent, so that Deloittte was liable to the receiver-manager for Livent. ... In rejecting this submission, Blair JA noted (at para. 113) that the rationale for such an illegality (or “ ex turpi causa ”) defence “was to avoid “damage to the integrity of the legal system,” whereas this concern did not arise here as “the actual fraudsters will not profit from their wrongdoing and have not evaded criminal sanction…[n]or will Livent profit from the wrongdoing” (para. 156). ...
GST/HST Ruling
5 May 2014 GST/HST Ruling 152222 - […] [Public service bodies’ rebate of the provincial part of the HST – whether resident in a province]
The Association is a national organization composed of the provincial associations […] from several [participating and non-participating] provinces […]. ... There are […] directors/ trustees and like officials listed on the Association’s 2012 T1235, Directors/Trustees and Like Officials Worksheet, […]. ... Pursuant to […], […] [the Board of Directors determines the location of the head office] 13. ...
Conference
15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F - IFA 2020 Roundtable – T2057 & Functional Currency
15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Unedited CRA Tags 85; 261 Principal Issues: Whether the CRA can confirm in which currency amounts reported in form T2057 should be denominated in circumstances where section 85 applies in respect of a property transferred by a transferor that has a tax reporting currency different from that of the transferee. ... The first scenario of example 3 in paragraph 1.69 of the Folio S5-F4-C1 – Income Tax Reporting Currency (Feb. 27, 2019) provides an example of a situation where subsection 261(18) of the Act might be applicable. ...
Miscellaneous severed letter
14 May 1993 Income Tax Severed Letter 9313025 F - Acquisition and Disposition — Property — General
14 May 1993 Income Tax Severed Letter 9313025 F- Acquisition and Disposition — Property — General Unedited CRA Tags 54(c) 248(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Conference
19 November 2021 Roundtable, 2021-0914351C6 - 2021 TEI Conference – Q3(b)(i) – Form T2200
19 November 2021 Roundtable, 2021-0914351C6- 2021 TEI Conference – Q3(b)(i) – Form T2200 Unedited CRA Tags 8(1)(i)(iii), 8(2), 8(10), 8(13), 67 Principal Issues: How the employer should complete the answers to Question 10 on Form T2200 in the case where an employee has the option to work from home and that time is not tracked by the employer? ...
Technical Interpretation - External
21 April 1997 External T.I. 9707215 F - % coproduction differe % cout production
21 April 1997 External T.I. 9707215 F- % coproduction differe % cout production Unedited CRA Tags 125.4 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principales Questions: 125.4- % coproduction differe % participation depense Position Adoptée: De façon générale, le CI pour une société admissible correspond à 25% de sa "dépense de main-d'oeuvre admissible". ...
GST/HST Ruling
26 September 2014 GST/HST Ruling 156693 - AND INTERPRETATION – […] [Is a supply made by [the Charity] a service]
According to […], “[the Corporation] is the independent, non-profit organization that […]. [The Corporation] is independent from both the government and […].” 4. ... Schedule 1 to Program #2 Master Agreement indicates that the Charity is to deliver a […] service […] on behalf of the Corporation. ...
Excise Interpretation
3 January 2003 Excise Interpretation 42701 - Tariff Classification: " " Brought in Under Classification 2403.91.10 Not Subject to Customs Duty Equivalent to Excise Duty
3 January 2003 Excise Interpretation 42701- Tariff Classification: " " Brought in Under Classification 2403.91.10 Not Subject to Customs Duty Equivalent to Excise Duty Unedited CRA Tags ETA 23(2) XXXXX XXXXX XXXXX XXXXX Case: 42701January 3rd, 2003 Dear XXXXX This letter is in response to your email XXXXX concerning the importation of a product known as XXXXX and your request for a ruling on the tariff classification of this product. ... Sawab Nekiar, of the Customs Branch's Tariff Division, confirmed that XXXXX are classified under tariff item 2403.91.10 as "homogenized" or "reconstituted" tobacco "... suitable for use as wrapper tobacco. ...