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Conference summary

8 October 2010 Roundtable, 2010-0373691C6 F - T4A et T5018 - Honoraires -- summary under Subsection 238(2)

. The GST, HST, QST or provincial tax portion, if any, of the amount paid should not be reported on the T4A slip since it is not an amount under subsection 153(1) and is not required to be included in computing the recipient's income under the Act. ...
Conference summary

8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Subsection 246(1)

. [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Conference summary

8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Paragraph 12(1)(x)

. [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Technical Interpretation - External summary

28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Know-How and Training

. [W]here a source of income exists, either property or business income, reasonable training expenses incurred by a taxpayer to earn income from that source are generally deductible to the extent that they do not produce a lasting benefit to the taxpayer. ...
Technical Interpretation - Internal summary

12 January 2011 Internal T.I. 2010-0375801I7 F - Bien agricole admissible détenu avant 1987 -- summary under Subparagraph 110.6(1.3)(c)(ii)

The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...
Technical Interpretation - External summary

12 December 2016 External T.I. 2016-0668341E5 F - Stock dividend -- summary under Paragraph 55(2.3)(b)

CRA noted that, by virtue of s. 55(2.2) the amount of the dividend (which otherwise would be $1) would be deemed to be $700,000 for purposes of s. 55(2) to (2.4) and given that the safe income on the Class A shares would be reduced by $700,000 under s. 55(2.3)(b), the ACB of the preferred shares also would be $700,000. ...
Technical Interpretation - Internal summary

14 September 2016 Internal T.I. 2016-0631631I7 - Transfer pricing capital adjustment -- summary under Subsection 247(3)

. [T]he only significance of the fact that the penalty is assessable in respect of Year X and not Year X+7 is… the de minimis rule in paragraph 247(3)(b)…. ...
Conference summary

29 November 2016 CTF Roundtable Q. 11, 2016-0669761C6 - Computation of Earnings for LLCs -- summary under Subparagraph (a)(iii)

LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) earnings- s. ...
Conference summary

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F - Individuals separated living under the same roof -- summary under Cohabiting Spouse or Common-Law Partner

. Where a taxpayer and the taxpayer’s ex-spouse or former common-law partner state that they are living at the same address, but consider themselves as merely roommates from the date of separation, the following documents may support a request for validation: Divorce document; A court order or a legal separation agreement that sets out legal details of the arrangements for the individuals, child custody and provision for child support; Other legal documents; Mortgage documents showing the assumption of the entire mortgage by one of the parties and the effective date of the change; Proof of individual vehicle loans indicating the effective date of the change, if applicable; Proof of automobile insurance for each former spouse or common-law partner indicating the effective date of the change (from family to individual); Proof of individual medical insurance indicating the effective date of the change or the date the spouse or common-law partner was removed from the client's file; Individual credit card statements indicating the effective date of the change, if applicable; Letter from an independent third party, supplemented by persons in authority, attesting that the two individuals live at the same address but live separate and apart and no longer appear as a couple since a certain date. ...
Technical Interpretation - External summary

17 February 2017 External T.I. 2015-0602781E5 - Disposition of farm property by a non-resident -- summary under Subsection 116(4)

. If a gain were to result, an amount in respect of tax, or acceptable security, would be required to be remitted. ...

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