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Technical Interpretation - External summary
28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Subsection 20(10)
. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ...
Technical Interpretation - External summary
21 April 2010 External T.I. 2009-0341711E5 F - Déduction pour gains en capital -- summary under Paragraph 110.6(14)(d)
Respecting the trust beneficiary scenario, CRA stated, before concluding that “the Act allows a beneficiary of a trust, who is a member of a partnership that disposes of QSBCSs, to benefit from the capital gains deduction under subsection 110.6(2.1) if the capital gain is designated by virtue of subsection 104(21.2): [G]enerally, subsection 104(2) provides that for the purposes of the Act “a trust shall … be deemed to be in respect of the trust property an individual….” ...
Technical Interpretation - External summary
28 June 2010 External T.I. 2010-0357081E5 F - Crédit d'impôt pour la rénovation domiciliaire -- summary under Paragraph (b)
. … If the move occurs after the eligible period, in this example in March 2010, the unit will not be an eligible dwelling of the individual or a qualifying relation of the individual since it will not have been ordinarily occupied during the eligible period. ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0357071E5 F - Crédit d'impôt pour l'achat d'une 1e habitation -- summary under Subparagraph (a)(i)
19 May 2010 External T.I. 2010-0357071E5 F- Crédit d'impôt pour l'achat d'une 1e habitation-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home- Paragraph (a)- Subparagraph (a)(i) given future intention test, there can be a gap between purchase and home becoming principal residence Can an individual otherwise satisfying the conditions claim the HBTC if the individual acquired a residence on December 15, 2009, but did not live in it before February 1, 2010 (and may have renovated it during that period) – and can there be a gap between the time of the home’s purchase and it becoming the individual’s principal place of residence? ...
Technical Interpretation - External summary
6 December 2016 External T.I. 2015-0589041E5 F - Frais médicaux payés d’avance - prepaid medical expenses -- summary under Subsection 118.2(1)
. … For example, where an individual chooses the period from January 1 to December 31, 2016…[i]f the…fees were paid on December 31, 2015, they would not be eligible for the METC computation for the 2016 taxation year…. ...
Technical Interpretation - External summary
19 December 2016 External T.I. 2016-0643191E5 F - Deferred Salary Leave Plan (DSLP) -- summary under Paragraph 8(1)(n)
19 December 2016 External T.I. 2016-0643191E5 F- Deferred Salary Leave Plan (DSLP)-- summary under Paragraph 8(1)(n) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) deduction where “repayment” of advances made during employee leave In the course of a comprehensive discussion of the deferred salary leave plan (“DSLP”) rules in Reg. 6801(a), CRA provided an example of an arrangement in which, during an employee leave, the employee first receives amounts whose recognition was deferred under the DSLP rules, and then receives advances of salary or wages which are to be earned after returning – with CRA stating that both types of amounts “must be included in the employee's income in the leave year under subsections 6(3) and 5(1).” ...
Technical Interpretation - External summary
19 January 2017 External T.I. 2015-0576751E5 F - Trust, Disposition of depreciable property, Assumption -- summary under Paragraph 13(7)(e)
. … [T]he context and wording of the preamble to subsection 107(2.1) and paragraph (c) of the definition of disposition in subsection 248(1) provide a basis for concluding that the trust is deemed to have disposed of the property in favour of the beneficiary by virtue of paragraph (a) and that, under paragraph (b), the beneficiary is deemed to have acquired the property of the trust. ...
Technical Interpretation - External summary
13 February 2017 External T.I. 2015-0570011E5 - Compensation by non-resident-loss of rental income -- summary under Paragraph 212(1)(d)
. … When an amount is paid to a taxpayer in a year to compensate for the loss of rental income, [CRA] would generally consider the compensation to be rental income for that year. ...
Technical Interpretation - External summary
20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules -- summary under Subsection 90(9)
. … ...
Technical Interpretation - External summary
14 March 2017 External T.I. 2016-0627311E5 F - Deduction of contribution to an IPP or RCA -- summary under Salary Deferral Arrangement
. … In general, supplementary pension benefits are considered to be reasonable when the terms of the supplemental pension plan are substantially the same as those of the IPP. ...