Search - 辐射监测仪 校准
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Technical Interpretation - External summary
18 May 2004 External T.I. 2004-0069691E5 F - Incorporation des professionnels -- summary under Section 34
. … The election … is therefore not permitted …. Words and Phrases accountant ...
Technical Interpretation - External summary
1 May 2020 External T.I. 2020-0846931E5 - CEWS - public institution -- summary under Paragraph (a)
We consider that the following factors would be relevant in making such determination: • the identity of members, • the structure of the corporation, • who exercises control over the financing, operation and direction of the corporation, • who has the right to elect or change the board of directors or to reverse its decision, • who can contribute capital and receive a distribution of capital, • details regarding asset distribution on winding-up or dissolution and • whether a person other than her Majesty in right of Canada, a province or a Canadian municipality has any right to acquire any capital of the corporation. ...
Technical Interpretation - External summary
19 December 2008 External T.I. 2008-0299321E5 F - Exploitation forestière et DBFT -- summary under Canadian Manufacturing and Processing Profits
CRA stated: Corporation B's activities are limited to the provision of services on behalf of others as a subcontractor and … the profits earned by Corporation B are not manufacturing and processing profits in Canada. …. However … it is possible that the subcontracting costs paid by Corporation A to Corporation B could be included in the "cost of manufacturing and processing labour" as defined in [Reg.] 5202 …. ...
Technical Interpretation - External summary
19 December 2008 External T.I. 2008-0299321E5 F - Exploitation forestière et DBFT -- summary under Cost of Manufacturing and Processing Labour
CRA stated: Corporation B's activities are limited to the provision of services on behalf of others as a subcontractor and … the profits earned by Corporation B are not manufacturing and processing profits in Canada. …. However … it is possible that the subcontracting costs paid by Corporation A to Corporation B could be included in the "cost of manufacturing and processing labour" as defined in [Reg.] 5202 …. ...
Technical Interpretation - External summary
7 January 2009 External T.I. 2008-0286111E5 F - 88(1)d) and 87(11)-Late-filed designation -- summary under Paragraph 88(1)(d)
. … [T]he CRA [will not] accept a late designation if it is for retroactive tax planning purposes, if the designation is part of a tax avoidance scheme, or if it is necessary, in order to give effect to the designation, to issue a … reassessment … [where] the normal reassessment period … has expired. ...
Technical Interpretation - External summary
16 March 2011 External T.I. 2010-0380571E5 F - Application de 251(5)b)(ii) et 256(1.4)b) -- summary under Subparagraph 251(5)(b)(ii)
CRA responded: [Ss.] 251(5)(b)(ii) and … 256(1.4)(b) … [are] broad enough to apply to a situation where a particular person does not have control over the triggering of an event that would entitle that person to require a corporation to redeem, acquire or cancel shares of its capital stock owned by another shareholder. … In addition, the CRA has ruled … that those two provisions generally should not apply to a situation where a corporation is required to redeem or cancel shares of its capital stock held by a shareholder who has been found guilty of fraud in relation to the corporation. … [See] F 2002-0172315 and F 2006-0167361E5. ...
Technical Interpretation - Internal summary
19 June 2001 Internal T.I. 2000-0053887 F - STATUTE-BARRED YEARS - GST CREDIT -- summary under Subsection 152(4)
James, 66 DTC 5241for the proposition that “a request for an adjustment to the computation of net income to create a non-capital loss or increase such loss by taking into account the business losses realized during the 1995, 1996 and 1997 taxation years would be acceptable even if a new notice of assessment cannot be issued for those years,” and then stated: Pursuant to subsection 122.5(3), the GSTC is an amount “deemed to have paid during the specified month on account of their tax payable under this Part for the taxation year …”. Under subsection 152(1), the Minister reviews the return of income, assesses the tax and determines “the amount of tax … deemed by subsection … 122.5(3) … to be paid on account of the taxpayer’s tax payable under this Part for the year.” ...
Technical Interpretation - External summary
13 October 2010 External T.I. 2010-0366801E5 F - Impôt minimum à reporter/réduction d'impôt -- summary under Subsection 153(1.1)
. … Where a taxpayer has an alternative minimum tax balance to carry forward … CRA … will agree to consider the taxpayer's request to reduce tax deductions at source for one of the years to which such balance can be carried forward. ...
Technical Interpretation - Internal summary
24 September 2020 Internal T.I. 2020-0841041I7 - Normal reassessment period - provincial tax -- summary under Subsection 152(4)
. … [W]here a trust files a T3 return and does not report having a permanent establishment or income in a particular Agreeing Province … the trust has reported nil income with respect to the particular province or territory. Furthermore, the resulting Notice of Assessment or notice of no tax payable is considered to include a notice of no tax payable in respect of the Agreeing Province. … Accordingly … the federal assessment constitutes a Notice of Assessment or notification of provincial or territorial tax for all Agreeing Provinces. ... This view is consistent with … Aubrey Dan Family Trust …. Words and Phrases agreeing province ...
Technical Interpretation - External summary
22 January 2020 External T.I. 2014-0559281E5 F - T5008 -- summary under Subsection 49(1)
22 January 2020 External T.I. 2014-0559281E5 F- T5008-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) writing of call option (with deemed nil ACB) is reported as having nil “cost” on T5008 Respecting the application of s. 49(1) to the writing and sale on an exchange of a naked call option and the reporting of the “cost” of the option on the T5008 issued by the securities dealer, CRA stated: [W]here an option is capital property … subsection 49(1) … provides (subject to the application of subsections 49(3) and 49(3.1) … and the exceptions in paragraphs 49(1)(a) to (c) …) that the granting of an option is equivalent to a disposition of property having an adjusted cost base of nil … [so that] there is no need to allocate cost to the option. ...