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Old website (cra-arc.gc.ca)
Excise and GST/HST News No. 70 (Fall 2008)
Incentive trips Under the Foreign Convention and Tour Incentive Program (FCTIP), a non-resident may claim a rebate in respect of the GST/HST paid on certain purchases made in connection with a foreign convention and on eligible tour packages. ... An incentive trip that includes business meetings is usually not a convention. ... It is always a question of fact whether any particular event or package would be a foreign convention or a tour package. ...
Old website (cra-arc.gc.ca)
International Transfer Pricing: Advance Pricing
Convention-- [NAME OF THE RELEVANT CONVENTION]. Critical assumption-- Any assumed objective criterion that would significantly affect the substantive terms of the APA if the underlying conditions changed, whether or not the change is within the taxpayer's control. ... Consequently, the confidentiality provisions of the Act and the Convention limit the rights and powers of the CCRA to use and disclose information submitted in connection with an APA. ... CHANGE IN LAW OR TO THE CONVENTION If there is a change in law or to the Convention that modifies the Canadian federal income tax treatment of any matter covered by this APA, the new or amended law or the Convention will supersede this APA to the extent that it is inconsistent. 19. ...
Current CRA website
International Transfer Pricing: Advance Pricing Arrangements (APAs)
Convention-- [NAME OF THE RELEVANT CONVENTION]. Critical assumption-- Any assumed objective criterion that would significantly affect the substantive terms of the APA if the underlying conditions changed, whether or not the change is within the taxpayer's control. ... Consequently, the confidentiality provisions of the Act and the Convention limit the rights and powers of the CCRA to use and disclose information submitted in connection with an APA. ... CHANGE IN LAW OR TO THE CONVENTION If there is a change in law or to the Convention that modifies the Canadian federal income tax treatment of any matter covered by this APA, the new or amended law or the Convention will supersede this APA to the extent that it is inconsistent. 19. ...
Current CRA website
International Transfer Pricing: Advance Pricing Arrangements (APAs)
Convention-- [NAME OF THE RELEVANT CONVENTION]. Critical assumption-- Any assumed objective criterion that would significantly affect the substantive terms of the APA if the underlying conditions changed, whether or not the change is within the taxpayer's control. ... Consequently, the confidentiality provisions of the Act and the Convention limit the rights and powers of the CCRA to use and disclose information submitted in connection with an APA. ... CHANGE IN LAW OR TO THE CONVENTION If there is a change in law or to the Convention that modifies the Canadian federal income tax treatment of any matter covered by this APA, the new or amended law or the Convention will supersede this APA to the extent that it is inconsistent. 19. ...
Old website (cra-arc.gc.ca)
Excise and GST/HST News No. 65 (Summer 2007)
GST/HST Info Sheets GI-015 GST/HST Rate Reduction and Purchasers of New Housing – July 2007 (revised) GI-035 Annual Information Schedule for Financial Institutions GI-036 Beverages GI-037 Children's Camps Operated by Public Sector Bodies GST/HST Memorandum 4-4 Agriculture and Fishing (revised) GST/HST Guides RC4160 Rebate for Tour Packages, Foreign Conventions, and Non-Resident Exhibitor Purchases (revised) GST/HST Technical Information Bulletin (TIB) B-096 GST/HST Rate Reduction and Real Property GST/HST Policy Statements P-196R Whether Administrative Overhead Costs Fall under Subsection 186(1) of the Excise Tax Act (revised) P-218R Tax Status of Damage Payments, Whether or not Within Section 182 of the Excise Tax Act (revised) GST/HST Notices NOTICE221 Questions and Answers on the Cancellation of the Visitor Rebate Program and the New Foreign Convention and Tour Incentive Program (revised) GST/HST Forms GST60 GST/HST Return for Acquisition of Real Property (revised) GST111 Schedule 1 – Financial Institution GST/HST Annual Information Schedule GST115 GST/HST Refund Application for Tour Packages GST386 Refund application for foreign conventions GST489 Return for Self-Assessment of the Provincial Part of Harmonized Sales Tax (HST) (revised) Excise Duty Memorandum EDM10-3-1 Refunds (revised) Softwood Lumber Products Export Charge Forms B253-1 Softwood Lumber Products Export Charge – Independent Remanufacturer Registration Supplement (revised) B278 Softwood Lumber Products Export Charge Act, 2006 – Application for Refund (revised) All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at: www.cra-arc.gc.ca/tax/technical/menu-e.html GST/HST Enquiries To make enquiries regarding your GST/HST account, call Business Enquiries at 1-800-959-5525 To make enquiries regarding the status of specific GST/HST domestic rebate claims, call 1-800-565-9353 To make enquiries regarding the status of visitor rebate claims, call 1-800-668-4748 To obtain copies of forms and publications, call 1-800-959-2221 If you are in Quebec please call the following toll-free number: 1-800-567-4692 (Revenu Québec) The Excise and GST/HST News is published quarterly and highlights recent developments in the administration of the goods and services tax (GST) and harmonized sales tax (HST) as well as excise taxes and duties. ...
Archived CRA website
ARCHIVED - Income Tax - Technical News No. 30
The Commentary to Article 1 of the OECD Model Tax Convention on Income and on Capital states, in part, at paragraph 9.4: … it is agreed that states do not have to grant the benefits of a double taxation convention where arrangements that constitute an abuse of the provisions of the convention have been entered into. ... However, in the Canada-U.S tax convention, Canada has specifically agreed to give a foreign tax credit for payments under the Federal Insurance Contributions Act, more commonly known as FICA taxes. ...
Scraped CRA Website
ARCHIVED - Income Tax - Technical News No. 30
The Commentary to Article 1 of the OECD Model Tax Convention on Income and on Capital states, in part, at paragraph 9.4: … it is agreed that states do not have to grant the benefits of a double taxation convention where arrangements that constitute an abuse of the provisions of the convention have been entered into. ... However, in the Canada-U.S tax convention, Canada has specifically agreed to give a foreign tax credit for payments under the Federal Insurance Contributions Act, more commonly known as FICA taxes. ...
Archived CRA website
ARCHIVED - Income Tax - Technical News No. 30
The Commentary to Article 1 of the OECD Model Tax Convention on Income and on Capital states, in part, at paragraph 9.4: … it is agreed that states do not have to grant the benefits of a double taxation convention where arrangements that constitute an abuse of the provisions of the convention have been entered into. ... However, in the Canada-U.S tax convention, Canada has specifically agreed to give a foreign tax credit for payments under the Federal Insurance Contributions Act, more commonly known as FICA taxes. ...
Archived CRA website
ARCHIVED - Income Tax - Technical News No. 44
Paid-Up Capital Increase by an Unlimited Liability Company Question The policy underlying Article IV(7)(b) of the Canada-US income tax convention [Footnote 10] is not obvious. ... [Footnote 12] Convention Between Canada and the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, signed at Luxembourg on September 10, 1999. ... [Footnote 17] IC 76-12R6, Applicable Rate of Part XIII Tax on Amounts Paid or Credited to Persons in Countries with Which Canada Has a Tax Convention, November 2, 2007. ...
Scraped CRA Website
ARCHIVED - Income Tax - Technical News No. 44
Paid-Up Capital Increase by an Unlimited Liability Company Question The policy underlying Article IV(7)(b) of the Canada-US income tax convention [Footnote 10] is not obvious. ... [Footnote 12] Convention Between Canada and the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, signed at Luxembourg on September 10, 1999. ... [Footnote 17] IC 76-12R6, Applicable Rate of Part XIII Tax on Amounts Paid or Credited to Persons in Countries with Which Canada Has a Tax Convention, November 2, 2007. ...