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GST/HST Interpretation

23 September 1996 GST/HST Interpretation 11640-3[8] - Services Provided to Refugee Claimants

You are specifically concerned about the services of assisting refugee claimants in the preparation for and presentation of their applications for Convention Refugee Status to the Immigration and Refugee Board (IRB). ... The services your firm's client performs, i.e., assisting refugee claimants in the preparation for and presentation of their applications for Convention Refugee Status to the IRB, appear to be advisory and consulting services. ...
GST/HST Interpretation

26 November 1997 GST/HST Interpretation HQR0000889 - Demande de décision/interprétation

26 November 1997 GST/HST Interpretation HQR0000889- Demande de décision/interprétation Unedited CRA Tags LTA 123; LTA 349; LTA 356 Direction des décisions et de l'interprétation de la TPS/TVH Place Vanier, Tour C, 10e étage 25, avenue McArthur Vanier (Ontario) K1A 0L5 XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX Cas no: HQR0000889Dossier no: 11590-5le 26 novembre 1997  À l'attention de XXXXX Objet: DEMANDE DE DÉCISION/INTERPRÉTATION XXXXX Cher monsieur XXX, La présente fait suite à votre demande du 18 septembre 1997 concernant l'application de la taxe sur les produits et services/taxe de vente harmonisée (TPS/TVH) aux services fournis à une personne morale, soit XXXXX Notre compréhension des faits est la suivante: •   Le marché a été conclu entre XXXXX), une filiale en propriété exclusive de XXXXX de l'annexe A énonce les modalités de paiement et décrit les services devant être fournis par XXXXX en vertu de la convention. ... Analyse Aux termes de la convention conclue par XXXXX doit fournir des services, comme il est énoncé dans l'exposé des faits, qui consistent en le traitement automatisé des versements relativement aux paiements des clients de XXXXX Aux termes du paragraphe 123(1) de la Loi sur la taxe d'accise (LTA), la définition d'«effet financier» comprend un titre de créance. ...
Current CRA website

Transfer pricing

It aims to resolve situations where taxpayers are subject to tax as a result of an audit adjustment that is not in accordance with the provisions of the relevant tax convention, including situations of double taxation. ... Tax treaties – Canada has income tax conventions or agreements—commonly known as tax treaties—with many countries. ...
Old website (cra-arc.gc.ca)

Information for entities holding accounts with Canadian financial institutions

Tax Convention and the Standard for Automatic Exchange of Financial Account Information in Tax Matters, respectively. ... Tax Convention to determine if it can certify that it is not a specified U.S. person. ... Tax Convention, respectively. Also, see the following: Guidance on the Canada-U.S. ...
Current CRA website

Information for entities holding accounts with Canadian financial institutions

Tax Convention and the Standard for Automatic Exchange of Financial Account Information in Tax Matters, respectively. ... Tax Convention to determine if it can certify that it is not a specified U.S. person. ... Tax Convention, respectively. Also, see the following: Guidance on the Canada-U.S. ...
Old website (cra-arc.gc.ca)

Policy statement CPS-021, Registering charities that promote racial equality

Racial discrimination is an identified social problem prohibited by an international convention to which most countries are signatories, making the promotion of racial equality an integral part of the public policy of many countries. ... Footnote 2 These criteria are consistent with the United Nations International Convention on the Elimination of all forms of Racial Discrimination. ... Footnote 4 Taken from the Canadian Anti-racism Education and Research Society: Defining Concepts and Terms Footnote 5 Taken from the International Convention on the Elimination of All Forms of Racial Discrimination, 21 December 1965, General Assembly resolution 2106 (XX). ...
Current CRA website

Registering charities that promote racial equality

Racial discrimination is an identified social problem prohibited by an international convention to which most countries are signatories, making the promotion of racial equality an integral part of the public policy of many countries. ... Return to footnote1 referrer Footnote 2 These criteria are consistent with the United Nations International Convention on the Elimination of all forms of Racial Discrimination. ... Return to footnote3 referrer Footnote 4 Taken from the Canadian Anti-racism Education and Research Society: Defining Concepts and Terms Return to footnote4 referrer Footnote 5 Taken from the International Convention on the Elimination of All Forms of Racial Discrimination, 21 December 1965, General Assembly resolution 2106 (XX). ...
Current CRA website

Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding

Income Tax Convention (“the Convention”). The LLC itself would have to attach Form NR303, Declaration of Eligibility for Benefits Under a Tax Treaty for a Hybrid Entity or equivalent information to the waiver application. On the other hand, if the LLC elects in the U.S. to be classified as a corporation and is taxable in the U.S. on its world income, it would be considered a resident of the U.S. for purposes of the Convention. ... LLC would be "liable to tax" in the U.S. for the purposes of paragraph 1 of Article IV of the Convention. ...
Old website (cra-arc.gc.ca)

Guidance CG-001, Upholding Human Rights and Charitable Registration

Definitions 3.1 Human rights For the purposes of this document, the term human rights refers to those individual rights and freedoms, within their prescribed limitations, set out in: Canadian law, including: the Canadian Charter of Rights and Freedoms the Canadian Bill of Rights the Canadian Human Rights Act provincial and territorial human rights legislation international treaties to which Canada is a party that come within the following categories: United Nations human rights covenants, conventions, and protocols International Labour Organization conventions Geneva conventions and protocols Other human rights references not listed may serve as the basis for a charity's work if the relevant parts of their content are sufficiently similar to the human rights and freedoms recognized by Canada in the above documents. 3.2 Upholding human rights For the purposes of this document, upholding human rights refers to activities that seek to encourage, support, and defend human rights that have been secured by law, both in Canada and abroad. ... When the English court decided the McGovern case in 1981, the United Kingdom had not yet ratified certain key human rights conventions or enacted measures to uphold the relevant human rights. ... Purposes may include, but are not limited to: monitoring and reporting on the fulfillment of human rights obligations (under convention or treaty x, in country or region y, or the whole world) upholding human rights law (under convention or treaty x, in country or region y, or the whole world) seeking legal remedies for victims of human rights abuses Example purpose and activities To uphold the administration and enforcement of (specify the international covenant or agreement) throughout the world, through the following activities: creating and disseminating reports that outline the progress of signatory countries on the administration and enforcement of the (specified covenant or agreement) providing training to government officials, lawyers, and judges in countries that are signatory to the (specified covenant or agreement) providing well-reasoned commentary and recommendations to the signatory governments about the implementation of the (specified covenant or agreement) providing legal advice and representation to victims of violations of the (specified covenant or agreement) for attempts to obtain remedies through the courts of the country concerned or any available international remedies Preserving human life and health In these cases, the focus will tend to be on the victims of human rights abuses. ...
Current CRA website

Upholding human rights and charitable registration

Definitions 3.1 Human rights For the purposes of this document, the term human rights refers to those individual rights and freedoms, within their prescribed limitations, set out in: Canadian law, including: the Canadian Charter of Rights and Freedoms the Canadian Bill of Rights the Canadian Human Rights Act provincial and territorial human rights legislation international treaties to which Canada is a party that come within the following categories: United Nations human rights covenants, conventions, and protocols International Labour Organization conventions Geneva conventions and protocols Other human rights references not listed may serve as the basis for a charity's work if the relevant parts of their content are sufficiently similar to the human rights and freedoms recognized by Canada in the above documents. 3.2 Upholding human rights For the purposes of this document, upholding human rights refers to activities that seek to encourage, support, and defend human rights that have been secured by law, both in Canada and abroad. ... When the English court decided the McGovern case in 1981, the United Kingdom had not yet ratified certain key human rights conventions or enacted measures to uphold the relevant human rights. ... Purposes may include, but are not limited to: monitoring and reporting on the fulfillment of human rights obligations (under convention or treaty x, in country or region y, or the whole world) upholding human rights law (under convention or treaty x, in country or region y, or the whole world) seeking legal remedies for victims of human rights abuses Example purpose and activities To uphold the administration and enforcement of (specify the international covenant or agreement) throughout the world, through the following activities: creating and disseminating reports that outline the progress of signatory countries on the administration and enforcement of the (specified covenant or agreement) providing training to government officials, lawyers, and judges in countries that are signatory to the (specified covenant or agreement) providing well-reasoned commentary and recommendations to the signatory governments about the implementation of the (specified covenant or agreement) providing legal advice and representation to victims of violations of the (specified covenant or agreement) for attempts to obtain remedies through the courts of the country concerned or any available international remedies Preserving human life and health In these cases, the focus will tend to be on the victims of human rights abuses. ...

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