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Administrative Policy summary

S3-F3-C1 - Replacement Property -- summary under Subsection 44(6)

S3-F3-C1- Replacement Property-- summary under Subsection 44(6) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(6) Reallocation under s. 44(6) 1.18 [U]nder subsection 44(6), a taxpayer may be permitted to reallocate the POD of a former business property composed of land and one or more buildings between the land component and the building component. ...
Administrative Policy summary

GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025 -- summary under Subsection 22(1)

. Application of general rules 14. If these rules do not determine the place of supply of the transportation pass (for example, where the passenger transportation services covered by the passenger transportation pass may not always begin in the same participating province), the place of supply is determined under the general place of supply rules for intangible personal property. ...
Administrative Policy summary

IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998 -- summary under Paragraph 214(3)(a)

IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) No penalty if tax remitted by Feb 15/based only on net annual increase in balance 38....If there is no series of loans or other transactions and repayments (see 28 above), the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the taxation year of the lender, in order to determine if the exception under subsection 15(2.6) applies. ...
Administrative Policy summary

IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences" -- summary under Class 14

Where renewal or extension periods are considered part of the life of the property under the criteria set out in 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ...
Administrative Policy summary

8 July 2013 Interpretation Case No. 145134 -- summary under Section 181.1

. [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...
Administrative Policy summary

Taxable Supplies - Special Cases [CRA website] -- summary under Subsection 153(1)

. Tips and gratuities …A tip or gratuity that is freely given by a customer, for example, cash not recorded on a bill, is not subject to the GST/HST. ...
Administrative Policy summary

2 December 2014 CTF Roundtable, Q. 9 -- summary under Paragraph 95(6)(b)

However, paragraph 95(6)(b) could still apply in other contexts such as… the manipulation of a taxpayer's participating percentage in a controlled foreign affiliate. ...
Administrative Policy summary

31 October 2011 Interpretation Case No. 132880 -- summary under Financial Service

In such a case, there must be a direct and clear connection between the payment made to the Dealer (lump-sum or periodic) and the services provided in relation to the initial sale of the […] Shares to the Client. ...
Administrative Policy summary

New position on private health services plans - Questions and answers 25 November 2015 -- summary under Subparagraph 6(1)(a)(i)

. $70 relates to coverage for prescription drugs that an employee lawfully buys, as prescribed by a medical practitioner and recorded by a pharmacist;…$20 relates to coverage for dental services paid to a dentist;…$8 relates to coverage for medical tests such as electrocardiograms, urine analysis, and x-rays; and…$2 relates to coverage for non-prescription vitamins. ...
Administrative Policy summary

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)" -- summary under Paragraph 217.1(1)(b)

Bulletin B-095 June 2011 "The Self-assessment Provisions of Section 218.01 and Subsection 218.1(1.2) for Financial Institutions (Import Rules)"-- summary under Paragraph 217.1(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 217.1- Subsection 217.1(1)- Paragraph 217.1(1)(b) Ss. 132(2) and (3) rules do not apply for purposes of s. 217.1(1)(b)(i) Qualifying taxpayer The reference to being resident in Canada in the definition of "qualifying taxpayer" does not include a non-resident with a permanent establishment under subsection 123(1) in Canada where that person is deemed under subsection 132(2) to be resident in Canada with respect to activities of the person carried on through the establishment. ...

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