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Technical Interpretation - Internal

14 July 2004 Internal T.I. 2004-0072241I7 - Provincial ITC & 12(1)(x)

14 July 2004 Internal T.I. 2004-0072241I7- Provincial ITC & 12(1)(x) Unedited CRA Tags 12(1)(x) 9 Principal Issues: 1.application date of tax credit; 2.whether section 9 vs. 12(1)(x) applies Position: 1. see ITTN 29; 2.in this case section 12(1)(x) is applicable Reasons: 1. policy carefully formulated in ITTN 29; 2. in keeping with policy in IT273R2- paragraph 17 July 14, 2004 SR&ED Directorate HEADQUARTERS Mel Machado L.Holloway CA Financial Legislative Directorate (613) 957-2104 50 O'Connor Street, 7th Floor Attention: Kevin Gibson 2004-007224 Income Inclusion of British Columbia Investment Tax Credit on the Prescribed Proxy Amount ("BC ITC") We are writing in response to your memorandum dated April 19, 2004 requesting our views on the timing of income recognition in respect of provincial government assistance. Your enquiry concerns the policy stated in Income Tax Technical News # 29 ("ITTN 29") and in particular, its application to the BC ITC. ... For example, this issue is raised in SR & ED Application Policy paper 2000-03 dated October 31, 2000 entitled "Government Assistance Treatment of Provincial and Territorial R&D". ...
Technical Interpretation - Internal

21 May 1998 Internal T.I. 9808507 - QUALIFIED INVESTMENTS - DIAMONDS & SPIDERS

21 May 1998 Internal T.I. 9808507- QUALIFIED INVESTMENTS- DIAMONDS & SPIDERS Unedited CRA Tags 146(1) 204 4900(1) 3201(o)(ix) 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. ...
Technical Interpretation - Internal

26 April 1994 Internal T.I. 9408847 - RETIRING ALLOWANCE & LIEU OF NOTICE PAYMENT

26 April 1994 Internal T.I. 9408847- RETIRING ALLOWANCE & LIEU OF NOTICE PAYMENT Unedited CRA Tags 248(1) 146(1)(c) 60(j.1) 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. ...
Technical Interpretation - Internal

10 February 1995 Internal T.I. 9431726 - ALLOWANCE & SALARY FOR GROUP HOME FOSTER CARE

10 February 1995 Internal T.I. 9431726- ALLOWANCE & SALARY FOR GROUP HOME FOSTER CARE Unedited CRA Tags 5 81(1)(h) 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. ...
Technical Interpretation - Internal

30 June 1995 Internal T.I. 9515917 - capital gains election & trusts

30 June 1995 Internal T.I. 9515917- capital gains election & trusts Unedited CRA Tags 110.6(19) 104(21.2) 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. ...
Technical Interpretation - Internal

21 July 2003 Internal T.I. 2003-0183657 - Section 217 Election & Workers Comp217

21 July 2003 Internal T.I. 2003-0183657- Section 217 Election & Workers Comp217 Also released under document number 2003-01836570. ...
Technical Interpretation - Internal

10 May 2001 Internal T.I. 2001-0065827 F - FINES + PENALTIES - INTÉRETS ET PÉNALITÉS

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS Unedited CRA Tags 18(1)a) 18(1)t) 18(1)b) 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. ...
Technical Interpretation - Internal

24 June 2002 Internal T.I. 2002-0147387 - TRAVEL & VEHICLE EXP. SPECIAL DUTY PAY

24 June 2002 Internal T.I. 2002-0147387- TRAVEL & VEHICLE EXP. SPECIAL DUTY PAY Unedited CRA Tags 8(1)(h) 8(1)(h.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...
Technical Interpretation - Internal

14 December 2009 Internal T.I. 2009-0333931I7 - Education & Tuition Credit, licence fee deduction

14 December 2009 Internal T.I. 2009-0333931I7- Education & Tuition Credit, licence fee deduction Unedited CRA Tags 8, 18, 118.5; 118.6 Principal Issues: 1. ... December 14, 2009 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Income Tax Rulings Client Relations Directorate Directorate Corporate Strategies and Renee Sigouin Business Development Branch (613) 957-2128 ` Attention: XXXXXXXXXX XXXXXXXXXX 2009-033393 Fees paid for courses, exams and licences We are writing in response to your email correspondence dated July 24, 2009 wherein you requested our comments with respect to whether individuals (the "Individuals") taking a particular course and related exam are entitled to claim an education tax credit and/or tuition tax credit and additionally, whether certain licence fees are deductible for income tax purposes. ...
Technical Interpretation - Internal

13 May 2002 Internal T.I. 2002-0116807 - M & P - COST OF LABOUR

13 May 2002 Internal T.I. 2002-0116807- M & P- COST OF LABOUR Unedited CRA Tags 125.1 5202 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... DISCUSSION The relevant portion of the definition of "cost of labour" of a corporation for a taxation year in section 5202 of the Regulations provides as follows: " an amount equal to the aggregate of (a) the salaries and wages paid or payable during the year to all employees of the corporation for services performed during the year, and (b) all other amounts each of which is an amount paid or payable during the year for the performance during the year, by any person other than an employee of the corporation, of functions relating to (i) the management or administration of the corporation, (ii) scientific research and experimental development, or (iii) a service or function that would normally be performed by an employee of the corporation. ...

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