Search - 赤峰 二中 初中学区划分 2005

4 November 2005-- summary under Section 20 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part VI- Section 20 Legislative framework An “other body established by a government” may make certain supplies of a regulatory or administrative nature on an exempt basis pursuant to section 20 of Part VI of Schedule V and section 189.1 of the ETA. ... The term “other body established by a government” is also found in other provisions …. ... It should be noted that this category does not include a body that is incorporated pursuant to-the authority of a statute that provides the legal basis for and a scheme for incorporation e.g., … the Canada Corporations Act …. ...

P-208R "Meaning of Permanent Establishment in Subsection 123(1) of the Excise Tax Act (the Act)" 23 March 2005-- summary under Permanent Establishment Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Permanent Establishment Meaning of fixed place of business …The fact that space at the disposal of a particular person is at the place of business of another person does not preclude the possibility that that space may be considered to be a place of business of the particular person … [f]or instance … space at the disposal of a non-resident at its client’s premises that is necessary for the non-resident to perform the service that it has agreed to supply to the client in the ordinary course of its business. … Space at the disposal of a person can also exist at the location of equipment or machinery that is at the disposal of the person. … The place of business must be “fixed” in that it must be established at a particular location with a certain degree of continuity and permanency. … [I]t is not necessary that the equipment be affixed to real property to be considered fixed. Rather, the equipment must merely remain at the place of business for a sufficient period of time to be considered fixed. … There must be control at the place of business. … Control can … exist at a place of business where employees are not required to be present in order for important operational decisions to be made, such as … where operational activities … are carried out through automated equipment at the disposal of the business. … The presence of personnel … is not required … if no personnel are required at that location to operate the equipment …. ... There must be a large degree of involvement through the fixed place of business in making or facilitating supplies by the person. … The presence of any of these factors is usually enough to indicate that supplies are being made through a fixed place of business: there is authority at the fixed place of business to enter into contracts or accept purchase orders for the provision of supplies to other persons and that authority is regularly exercised; the tangible personal property that is being supplied is physically manufactured or produced at the fixed place of business; if the supply is a service, the service is performed at the fixed place of business; or, the service of maintaining equipment supplied by the non-resident person, is performed at the fixed place of business (e.g., an authorized factory repair outlet). … A fixed place of business of a particular person that is used solely for the purpose of carrying on activities that are of a preparatory or auxiliary nature in relation to the particular overall business activity of the person does not constitute a fixed place of business of the person through which the person makes supplies. ...

3 March 2005 CBA Roundtable, Supplementary Q. 1—Q. 7-- summary under Subsection 167(1) Summary Under Tax Topics- Excise Tax Act- Section 167- Subsection 167(1) s. 167 not available re transferred partial JV interest that is immediately on-supplied A and B hold a 40% and 60% interest, respectively, in a joint venture. ... CRA responded: The following responses assume that where an arrangement is described as a joint venture in the question it has the characteristics of a joint venture as delineated in … P-103 …. ... With respect to the facts in this question: • The transfer by A to B of 25% interest would not meet the criteria for a section 167 election. • Assuming that B is transferring to C its entire interest when it transfers its 85% share, and that the supply is not from a registrant to a non-registrant, the supply would qualify for a section 167 election. • The transfer by A to C of its remaining entire 15% interest may qualify depending on the facts of the situation. ...

GST/HST Info Sheet GI-012, Agents, November 2005-- summary under Agency Summary Under Tax Topics- General Concepts- Agency Essential qualities of agency The three essential qualities are: consent of both the principal and the agent; authority of the agent to affect the principal's legal position; and the principal's control of the agent's actions. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

GST/HST Info Sheet GI-012, Agents, November 2005-- summary under Subsection 177(1) Summary Under Tax Topics- Excise Tax Act- Section 177- Subsection 177(1) Election under s. 177(1) [A] principal may elect to charge and account for the tax, instead of the agent, when the principal would otherwise not have to charge the tax. ... Essential qualities of agency The three essential qualities are: consent of both the principal and the agent; authority of the agent to affect the principal's legal position; and the principal's control of the agent's actions. … Authority of agent to bind principal When a person is acting as agent in making a transaction on behalf of a principal, the principal will generally authorize the agent to do something on the principal's behalf. … When a person is acting as agent in making a transaction on behalf of a principal, the agent will have the ability to affect the principal's legal position. The most common example of this is where the agent is authorized to enter into contracts with third parties on the principal's behalf. … [G]iving authority to a person to bind another person in a contract could indicate that a person is acting as agent in making a transaction on behalf of a principal. ...

GST New Memorandum 8.1, ITCs—General Eligibility Rules, May 2005-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) Meaning of “acquire” 9. ... Acquiror usually recipient 62. … The person that is eligible to claim the ITC for the tax paid or payable on the property or service is usually the recipient. ...

IC 05-1R1 "Electronic Record Keeping" June 2005-- summary under Subsection 230(4.1) Summary Under Tax Topics- Income Tax Act- Section 230- Subsection 230(4.1) 23. When original source documents and records are in an electronic format, they must be kept in an electronically readable format even if they have been transferred to another medium such as microfilm. … 25. ...

.$353M respecting CRA’s position that, pursuant to s. 247(2), Wheaton’s income should be increased by an amount equal to substantially all of the income earned outside Canada by such subsidiaries for the 2005 to 2010 taxation years. In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ... After application of the non-capital losses, Wheaton does not anticipate any additional cash taxes will arise in respect of the 2005 to 2010 taxation years as a result of the settlement. ...

Limitation Period on Discretion for Relief of Penalties and Interest ¶ 13. For income tax submissions made on or after January 1, 2005, the Minister's ability to grant relief is limited to any taxation year (or fiscal period in the case of a partnership) that ended within the previous 10 years before the calendar year in which the submission is filed. ... A disclosure must involve the application, or potential application of a penalty. … In the event a penalty does not apply, the taxpayer cannot seek relief through the VDP. … iv) One Year Past Due ¶ 39. ...