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Administrative Policy summary

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024 -- summary under Subsection 169(1)

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...
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 Section 4

. The expression not ordinarily located primarily means ordinarily located 50% or less. ...
Administrative Policy summary

28 May 2025 IFA Roundtable, Q.4 -- summary under Subsection 231.1(1)

Taxpayers are expected to have full access to the information pertaining to their obligations or entitlements under the ITA and to the extent these obligations are not met, CRA will exercise the powers under the ITA to enforce compliance with tax laws and maintain the integrity of the tax system. ...
Administrative Policy summary

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 -- summary under Recipient

. Accordingly, no GST/HST is applicable in respect of the taxable supply made by a solo miner that performs a mining activity and receives a mining payment before February 5, 2022. ...
Administrative Policy summary

25 February 2016 CBA Roundtable, Q. 4 -- summary under Subsection 317(3)

. 4(b) [Provincial exemptions] With the exception of Quebec, the CRA does not necessarily abide by the provincial exemptions when determining the rate to issue administrative garnishment action. ... Some examples…include situations where there were other sources of income and only one income source was to be subjected to garnishment action, assets that could be readily available to the debtor to generate funds to satisfy the tax debt in full or a substantial portion and the debtor was not cooperating, or situations where the provincial exemption amount would be insufficient to address the amount of arrears. [T]he CRA felt it was better to treat all debtors, in a similar circumstance, the same to the extent possible. ...
Administrative Policy summary

Non-Profit Organization Risk Identification Project Report 17 February 2014 -- summary under Paragraph 149(1)(l)

. A significant number of NPOs violate the incidental profit test or have large equity The results from the review of the randomly-selected organizations suggest that a significant portion of incorporated organizations would fail to meet at least one of the requirements set out in paragraph 149(1)(l)…. ...
Administrative Policy summary

IT-223 (Cancelled) "Overhead Expense Insurance vs. Income Insurance" 26 May 1975 -- summary under Income-Producing Purpose

. 3. Where the insurance policy provides a taxpayer carrying on business or practising a profession with a benefit for loss of income earning capacity such as income disability insurance, the premium on such a policy is a personal and living expense which is non-deductible and the benefit received by the taxpayer is not considered to be income subject to tax in his hands. 4. ...
Administrative Policy summary

6 June 2014 Interpretation 150533 -- summary under Subsection 162(2)

. Since B Co already owns the logs, the amounts paid by B Co are not consideration for a supply of logs by A Co but would appear to be [taxable] compensation paid to A Co for cutting the timber. ...
Administrative Policy summary

8 July 2013 Interpretation Case No. 145134 -- summary under Subsection 232(3)

. [I]f subsection 232(3) applies, then section 181.1 cannot apply by virtue of paragraph 181.1(d). ...

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