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Administrative Policy summary

Memorandum 8-3 - "Calculating Input Tax Credits" -- summary under Subsection 169(1)

. 57. A revenue-based method should be used with caution ...
Administrative Policy summary

7 April 2022 CBA Roundtable, Q.19 -- summary under Subsection 181(2)

Similar consequences would attend the redemption of loyalty points by a customer in exchange for a free service provided by Bco or the dealer except that, regarding Aco’s payment to Bco respecting the points redeemed by Bco, no ITC would be generated to Aco because s. 181(5)(c) would not be met. ...
Administrative Policy summary

CRA Webpage, "Notifiable transactions designated by the Minister of National Revenue," 15 August 2024 -- summary under Subsection 237.4(3)

CRA Webpage, "Notifiable transactions designated by the Minister of National Revenue," 15 August 2024-- summary under Subsection 237.4(3) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(3) Straddle transactions of FX-trading partnership (NT-2023-01) A taxpayer buys an interest in a partnership which, immediately prior thereto, had realized the gain legs on straddle transactions in FX forward contracts (with such gain allocated to the selling partner) and with the loss legs then being realized and allocated to the taxpayer. ...
Administrative Policy summary

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 -- summary under Subsection 200(2)

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025-- summary under Subsection 200(2) Summary Under Tax Topics- Excise Tax Act- Section 200- Subsection 200(2) Application of change-in-use rules as a result of virtual payment instruments becoming financial instruments on May 18, 2019 under " ITCs where virtual payment instruments are payable in respect of mining activities" Any capital property that the person held as of May 18, 2019, is subject to the change-in-use provisions in the ETA where supplies made after May 17, 2019, of the virtual payment instruments, acquired as a result of this mining activity, were not supplies made in the course of the person’s commercial activities. ...
Administrative Policy summary

GST/HST Notice 287 "CRA Administrative Positions on the Application of the Import Rules for Financial Institutions to Reinsurance Contracts" January 2015. -- summary under Loading

. The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ...
Administrative Policy summary

GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001 -- summary under Business

GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Appendix C General distinction between a regular business and an adventure General approach 3. ...
Administrative Policy summary

Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 263(3)

Mutual fund dealers whose clients invest with other FIs 6.2 Subsection 263(3) of the ITA makes clear that a financial account includes a client-name account maintained by a person or entity that is authorized under provincial law to engage in the business of dealing in securities or any other financial instrument or to provide portfolio management or investment advising services. ...
Administrative Policy summary

Dual-purpose payments -- summary under Subsection 6(3)

. Example 1: inclusion of signing bonus subject to repayment As an inducement to a prospective employee to accept an employment offer, an employer agrees to make a payment when the individual signs the employment contract. ...
Administrative Policy summary

15 December 2017 Information Circular - IC00-1R6 - Voluntary Disclosures Program -- summary under Subsection 220(3.1)

. 16. If a VDP application is accepted into the Limited Program, no interest relief will be provided. ...

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