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Administrative Policy summary

4 July 2013 Interpretation Case No. 144290 -- summary under Subsection 191(1)

. The Developer has only an interest in the Unit constructed on the Lot and cannot therefore dispose of something more (i.e., the Developer cannot make a separate sale of the building portion of the Unit). ...
Administrative Policy summary

4 July 2013 Interpretation Case No. 144290 -- summary under Paragraph 254.1(2)(d)

. The Developer has only an interest in the Unit constructed on the Lot and cannot therefore dispose of something more (i.e., the Developer cannot make a separate sale of the building portion of the Unit). ...
Administrative Policy summary

24 April 2015 Interpretation 166609 -- summary under Qualifying Member

. The CRA would generally review available documentation such as business plans or input tax credit claims and activities undertaken by the registrant to make taxable supplies such as research and marketing that support the expectation that the registrant will be making taxable supplies throughout the twelve months and that property acquired by the registrant within the twelve months is for use exclusively in its commercial activities. ...
Administrative Policy summary

GST/HST Technical Information Bulletin B-032 “Expenses Related to Pension Plans” 17 November 2015 -- summary under Recipient

. [T]he employer is entitled to claim an ITC in respect of the tax payable to the investment manager to the extent the investment management service is acquired for supply to the plan trust in the course of the employer’s commercial activities, provided that all of the conditions of section 169… are met. ...
Administrative Policy summary

26 February 2015 CBA Roundtable, Q. 6 -- summary under Sham

When the sham argument is used to support an audit assessment, AGP HQ is informed and works closely with the TSO in ensuring the two elements of sham are demonstrated and that our position is well supported. ...
Administrative Policy summary

21 February 2000 T.I. 1999-0010295 -- summary under Subsection 20(12)

. To the extent that the U.S. taxes are not used for claiming a foreign tax credit, they may be deducted under subsection 20(12)…. ...
Administrative Policy summary

8 June 2016 CTF Technical Seminar: Update on s. 55(2) -- summary under Paragraph 55(2.1)(b)

The changes to s. 55(2) were meant to address the type of planning raised by D & D Livestock, where ACB is created (without being caught by existing s. 55(2) because there was no gain on the shares in question). ...
Administrative Policy summary

5 February 2016 Interpretation 153241 -- summary under Section 5

. Accordingly, the supply of an IME by a medical practitioner is exempt under section 5…. ...
Administrative Policy summary

25 February 2016 CBA Roundtable, Q. 7 -- summary under Paragraph (c)

CRA indicated that it can accept such an arrangement as being valid notwithstanding that all of the source deductions are handled on the payroll account of only one of the dentists, who does the remittances, and source deduction and T4 reporting, as agent for the other dentists as well as on her own behalf and also pays the staff remuneration as agent and is reimbursed on a pro rata basis by the other dentists. ...
Administrative Policy summary

19 January 2017 Ruling 172004 -- summary under Supply

After ruling that the contributions to the Trust Fund made by the employers through the Organization pursuant to the collective agreements were not consideration for a supply, CRA stated: [T]he payment of amounts is an industry development fee set by [the Organization] which is authorized [under the Legislation] to do so […]. ...

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