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Technical Interpretation - Internal summary
2 May 2005 Internal T.I. 2005-0119971I7 F - CDA - Excessive Election & Late Filed Election -- summary under Subsection 83(3.1)
2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 83(3.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(3.1) where no s. 83(2) election filed for statute-barred year, CRA should request late election under s. 83(3.1) or, failing which, assess a taxable dividend under s. 184(4)(b)(ii) CRA never received a s. 83(2) election in respect of a dividend payable in 1997 by Yco to its sole shareholder, an individual ("Y"). ...
Technical Interpretation - External summary
1 February 2005 External T.I. 2004-0083921E5 F - Société mandataire, gain & CIÉ -- summary under Non-Business-Income Tax
1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent A corporation acquired a building in the US as agent for its individual shareholder pursuant to a nominee agreement. ...
TCC
Paris Ladouceur & Associés Inc. v. M.N.R., 2005 TCC 107
Signed at Ottawa, Canada, this 8th day of February 2005. “Louise Lamarre Proulx” Lamarre Proulx J. ... [23] The appeal is allowed. Signed at Ottawa, Canada, this 8th day of February 2005. “Louise Lamarre Proulx” Lamarre Proulx J. Translation certified true on this 13th day of July 2005. ...
Current CRA website
Evaluation study – Electronic services – Individual compliance behaviour – Tax return filing
The number of electronic tax returns processed has increased by 86% from 11.9 million in 2005 to 22.1 million in 2014. ... For the 2005 tax return filing season, 25.0 million tax returns were processed Footnote 5 compared to 28.3 million in 2014. ... (Figure D.4) Figure D.4 – Number and percentage of tax returns filed by youth and seniors and by filing method for tax year 2014 Age Category # of Returns Filed % of Paper % of Electronic – Total % of Electronic – NETFILE % of Electronic- EFILE Less than 20 1,120,329 21% 79% 23% 56% 65 + 5,774,836 22% 78% 20% 58% National total 27,835,591 16% 84% 28% 56% Source: 2014 Tax Returns Self-Employed The self-employed group was created by using the major source of income as reported on the 2014 tax return. ...
News of Note post
18 September 2017- 11:20pm SCDA (2005) – Federal Court of Appeal finds that s. 138(11.3) does not generate a basis bump in the 1st year a Canadian insurer carries on business in another country Email this Content Webb JA affirmed the interpretation below by Pizzitelli J of s. 138(11.3): there is no deemed disposition under s. 138(11.3) in the first year a Canadian insurer carries on business in another country, so that the taxpayer (Standard Life) did not enjoy a tax-free basis bump of $1.2B. ... Summaries of SCDA (2005) Inc. v. Canada, 2017 FCA 177 under s. 138(11.3) and Tax Court Rules, s. 147(3). ...
8 June 2014- 11:28pm Francis & Associates – Tax Court of Canada finds that substantively-correct bad debt deductions cannot be claimed in an amended return Email this Content Due to problems with its accounting system, a law firm did not discover until late in 2005 that billings made in 2002 to 2004 and which had become bad in those years had not been written off in the accounts. ... Summary of Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 under s. 20(1)(p)(i). ...
News of Note post
14 April 2025- 11:35pm Sura – Court of Quebec finds that the conversion of apartment buildings to condo units did not trigger a change of use – and that CAE rather than IT-218R would apply re change of use Email this Content In 1981, 10 individuals acquired as co-owners two adjoining rental buildings containing a total of 82 apartments. ... Revenue Quebec applied the position in IT-218R on change of use and treated such gains as consisting of a capital gain, computed on the basis of a notional disposition of the properties for their FMV the time of their change of use from capital property to inventory (in 2005, when the decision to convert was taken) and, as to the balance (representing post-2005 appreciation), as business income from the disposition of inventory. ...
FCA
Partylite Gifts Ltd. v. Canada (Customs & Revenue Agency), 2005 FCA 157
Canada (Customs & Revenue Agency), 2005 FCA 157 Date: 20050503 Docket: A-252-04 Citation: 2005 FCA 157 CORAM: ROTHSTEIN J.A. ... Judgment delivered from the Bench at Ottawa, Ontario, on May 3, 2005. REASONS FOR JUDGMENT OF THE COURT BY: NOËL J.A Date: 20050503 Docket: A-252-04 Citation: 2005 FCA 157 CORAM: ROTHSTEIN J.A. ...
Article Summary
Rod Butcher, "GST and Pensions - Back to the Future", GST & Commodity Tax, March 2005, p. 9. -- summary under Section 261.01
Rod Butcher, "GST and Pensions- Back to the Future", GST & Commodity Tax, March 2005, p. 9.-- summary under Section 261.01 Summary Under Tax Topics- Excise Tax Act- Section 261.01 ...