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Miscellaneous severed letter

28 July 1989 Income Tax Severed Letter 7-3924 - [Mine Reclamation Expenditures]

Paragraph 18(1)(m) of the Act provides that no deduction shall be made in respect of "... any amount... paid or payable by virtue of an obligation imposed by statute to (i) Her Majesty in right of... a province, (ii) an agent of Her Majesty in right of... a province, or (iii) a corporation, commission or association that is controlled by Her Majesty in right of.. a province or by an agent of Her Majesty in right of.. a province as a royalty, tax..., lease rental or bonus or as an amount, however described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or (v) the production in Canada of... (B) metal or minerals... from a mineral resource in Canada...". In order to be deductible such that paragraph 18(l)(m) of the Act did not apply, payments to the Fund would need to be something other than disguised royalties, taxes, lease rentals or bonuses. ... Yours truly, for Director Bilingual Services and Resource Industries Division Rulings Directorate ...
Miscellaneous severed letter

11 January 1989 Income Tax Severed Letter 5-7239 - [890111]

Paragraph 18(1)(m) provides that "... no deduction shall be made in respect of... any amount... paid or payable by virtue of an obligation imposed by statute... to (i) Her Majesty in right of... a province, (ii) an agent of Her Majesty in right of... a province, or (iii) a corporation, commission or association that is controlled by Her Majesty in right of.. a province or by an agent of Her Majesty in right of.. a province as a royalty, tax..., lease rental or bonus or as an amount, however, described, that may reasonably be regarded as being in lieu of any such amount, and that may reasonably be regarded as being in relation to (iv) the acquisition, development or ownership of a Canadian resource property, or (v) the production in Canada of... (B) metal or minerals... from a mineral resource in Canada...' In order to be deductible, paragraph 18(1)(m) notwithstanding therefore, payments to the funds would need to be something other than disguised royalties, taxes, lease rentals or bonuses. ... Yours truly, for Director Bilingual Services and Resource Industries Division Rulings Directorate ...
Miscellaneous severed letter

3 October 1989 Income Tax Severed Letter 7-4314 - Review of revision of IT-138R

Line 17 (paragraph 26)- The words "... taxation years and..." should be inserted immediately before "fiscal periods. ... Lines 1 to 8 (paragraph 29)- The sentence which describes the restriction is difficult to read and therefore we suggest replacing lines 1 to 8 with the following: "... periods ending after December 15, 1987. ... The various references in the bulletin to resource "expenditures" should be reworded as resource "expenses" in order to be consistent with the language used in the Act. ...
Miscellaneous severed letter

28 March 1990 Income Tax Severed Letter AC59499 - Admissibility of Flow-through Shares as Prescribed Shares

. $ 400 of the Unit price is attributable to the Class "A" common shares, or 20¢ per share. $4,600 of the total Unit price is attributable to the 46 Class "B" common shares, or $ 100 per share. ... The stated capital per share of the Class "B" common shares (i.e. $ 100 per share) will be divided by the current market price per Class "A" common shares into which each Class "B" common share is convertible. ... Yours truly Section Chief Resource Industries section Bilingual Services and Resource Industries Division Rulings Directorate Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...
Miscellaneous severed letter

3 October 1989 Income Tax Severed Letter AC74314 - Review of Revision of IT-138R

Line 17 (paragraph 26)- The words "... taxation years and..." should be inserted immediately before "fiscal periods. ... Lines l to8 (paragraph 29)- The sentence which describes the restriction is difficult to read and therefore we suggest replacing lines I to 8 uith the following: "... periods ending after December 15, 1987. ... The various references in the bulletin to resource "expenditures" should be reworded as resource "expenses" in order to be consistent with the language used in the Act. ...
Miscellaneous severed letter

22 May 1987 Income Tax Severed Letter

22 May 1987 Income Tax Severed Letter DATE May 22, 1987 TO- CURRENT AMENDMENTS & FROM- Bilingual Services REGULATIONS DIVISION Section G. ... Director Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch ...
Miscellaneous severed letter

3 July 1981 Income Tax Severed Letter

We discussed with Energy, Mines and Resources your concern over the fact that purchased scrap copper is introduced into the refining process. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch FLM/mor ...
Miscellaneous severed letter

6 March 1987 Income Tax Severed Letter 7-0580 - [XXXX]

Vallée (613) 957-8982 XXXX March 6, 1987 Dear Sir: Re: Canadian M & P Profits/Investment Tax Credit This is in reply to your letters of July 30, 1986 and October 2, 1986 and pursuant to our meeting of June 9, 1986. ... Yours truly, for Director Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch c.c. ...
Miscellaneous severed letter

7 December 1993 Income Tax Severed Letter 9331167 - Investment Tax Credit Qualified Transportation Equipment

December 7,1993 Winnipeg District Office Resource Industries B.A. Wood Section Business Enquiries Peter Lee (613) 957-8977 7-933116 Regulation 4601 Qualified Transportation Equipment This is in reply to your memorandum of October 29, 1993 wherein you requested a technical interpretation of the expression "carrying freight" for purposes of clause (c)(i)(B) of the above-mentioned Regulation in the context of a tow-truck which otherwise satisfies all of the requirements of the proposed amendments to section 127 of the Income Tax Act (the "Act") for purposes of the proposed small business investment tax credit and section 4601 of the Income Tax Regulations (the "Regulations") for treatment as "qualified transportation equipment". ... The Concise Oxford Dictionary, (8th ed 1990), defines the terms "carry" and "freight" as "transport in vehicle, ship, aircraft, hand or mind" and "goods transported; cargo... a load or burden", respectively. ... The Black's Law Dictionary, (6th ed 1990), defines the terms "carry" and "freight" as "to bear, bear about, sustain, transport, remove, or convey" and "goods transported by a carrier", respectively. ...
Miscellaneous severed letter

27 August 1980 Income Tax Severed Letter

If this classification is correct, the cost of assets used in such activities will qualify for inclusion in XXXX earned depletion base and class 28, and the income generated by such activities will qualify as resource profits within the meaning of Regulation 1204, from which the resource allowance may he deducted. ... The above view is consistent with the views of the Department of Finance and Energy, Mines and Resources, which Departments were consulted prior to the giving of the advance income tax ruling that was given to XXXX C. ... Since extraction (or mining) is viewed as ending at the pit's mouth, it is our view that "extraction from a mineral resource" includes only those activities that are related to the drawing forth of the ores from a mineral resource and that are conducted up to the pit's mouth or point of egress from the deposit. ...

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