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Administrative Policy summary

31 October 2023 Press Release, “Government of Canada extends deadline for homeowners to file their Underused Housing Tax return” -- summary under Paragraph 8(a)

. Consequently, the Canada Revenue Agency will waive the application of penalties and interest for any late-filed UHT returns and for any late-paid UHT payable for the 2022 calendar year, provided the return is filed and the UHT is paid by April 30, 2024. ...
Administrative Policy summary

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024 -- summary under Gross Revenue

IV of the Regs. 2.22 By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s. 248(1)] also applies for purposes of the Regulations. ...
Administrative Policy summary

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024 -- summary under Subsection 402(6)

When a corporation conducts all or part of its operations in partnership with one or more other persons, subsection 402(6) of the Regulations provides that for the purposes of subsection 402(3) the corporation must include in its gross revenue for the tax year and in its salaries and wages paid in the tax year its proportionate share of the gross revenue of the partnership and the salaries and wages paid by the partnership. ...
Administrative Policy summary

Selected listed financial institutions (SLFI), October 16, 2015 -- summary under Subsection 301(1.1)

. Quebec SLFI objection Effective January 1, 2013, the CRA administers the QST applicable to SLFIs. ...
Administrative Policy summary

GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025 -- summary under Subsection 22(1)

. Application of general rules 14. If these rules do not determine the place of supply of the transportation pass (for example, where the passenger transportation services covered by the passenger transportation pass may not always begin in the same participating province), the place of supply is determined under the general place of supply rules for intangible personal property. ...
Administrative Policy summary

17 June 2025 STEP Roundtable, Q.11 -- summary under Clause 256(7)(a)(i)(A)

In this case, a loss restriction event would occur as a result of the distribution of the shares except that control of the corporation will be deemed not to have been acquired if the individual beneficiary was related to each of the three trustees immediately before the distribution of the shares. ...
Administrative Policy summary

19 November 1996 Interpretation File No 11590-5 HQR0000358 -- summary under Subsection 185(1)

. [T]he redemption of the shares of the corporation is related to the commercial activities of the corporation. ...
Administrative Policy summary

S3-F3-C1 - Replacement Property -- summary under Subsection 44(6)

S3-F3-C1- Replacement Property-- summary under Subsection 44(6) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(6) Reallocation under s. 44(6) 1.18 [U]nder subsection 44(6), a taxpayer may be permitted to reallocate the POD of a former business property composed of land and one or more buildings between the land component and the building component. ...
Administrative Policy summary

9 October 2025 APFF Financial Planning Roundtable, Q.3 -- summary under Subsection 245(4)

CRA confirmed that this “series of transactions would not engage the application of the GAAR” notwithstanding the introduction of s. 245(4.1). ...
Administrative Policy summary

9 October 2025 APFF Financial Planning Roundtable, Q.3 -- summary under Subparagraph 20(1)(c)(i)

CRA confirmed that this “series of transactions would not engage the application of the GAAR” notwithstanding the introduction of s. 245(4.1) (but cautioned that its answer might differ if the series included other transactions). ...

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