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Miscellaneous severed letter
18 June 1990 Income Tax Severed Letter AC74490 - Capital Cost Allowance on Relocation Costs
Black's Law Dictionary defines "acquired" as follows: "... to get as one's own; to obtain... come to have... to become owner of property; to make property one's own. ... This position is supported at paragraph 3 of IT-417R where it states "... it is considered that the Income Tax Act always required and continues to require that all costs that could clearly be related to future periods be expensed in those periods, if they are material and if failure to defer the expense would distort the net profit not only of the year during which the expense was incurred but also of the subsequent year or years to which the benefit relates. ... Director Bilingual Services & 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
6 May 1983 Income Tax Severed Letter
Richardson Estate & Trust Audit HEAD OFFICE Specialized Audit Division Estate & Trust Group T. McDonald Reporting of Resource Income and Allowances We refer to your memorandum dated March 8 concerning the above topic. ...
Miscellaneous severed letter
1 June 1989 Income Tax Severed Letter 73896 F - Revision of Flow-through Share Forms T100, T101 and T102
G) Subsection 66(12.7) of the Act and section 228 of the Regulations provide statutory authority for filing Form T101 where there has been a renunciation of resource expenditures. ... Form T102 Summary I) Subsection 66(12.69) of the Act provides statutory authority for filing Form T102 Summary where there has been a renunciation of resource expenditures to a partnership. ... Chief Resource Industries SectionBilingual Services and ResourceIndustries Division ...
Miscellaneous severed letter
11 March 1987 Income Tax Severed Letter
11 March 1987 Income Tax Severed Letter DATE March 11, 1987 RESEARCH AND POLICY FILES Capital Cost Allowance Class 2, 8 & 29 FROM- D. ... The question has been looked at by the Services, Public Utilities & Exempt Corporations Section, the Merchandising, Manufacturing & Construction Section and, more recently, by the Resource Industries Section. ... Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Legislative and Intergovernmental Affairs Branch ...
Miscellaneous severed letter
11 December 1989 Income Tax Severed Letter 5-9063 - [Seminar on Tax Planning and Investment Strategy: Achieving Financial Independence at Retirement]
The financial counselling under discussion includes the following components: • a discussion of increasing life expectancy. the impact of inflation on financial resources, post-retirement expectations. • the level of income that can be expected from known sources such as the Public Service Pension Plan and other government sources (C.P.P./O.A.S.). • a net worth analysis showing the capability of deriving sufficient post-retirement income to cover anticipated expenses. • a discussion of present tax laws that provide investment opportunities as well as those that represent potential pitfalls to be avoided (all in legitimate tax planning terms). • a discussion on estate planing to advise how some of the common problems and costs can be avoided. • a case study providing the participant with an opportunity to apply basic financial planning principals to a set of circumstances. • an optional 90-minute private counselling session which focuses on the individual's particular circumstances. ... To that end the initial phase of discussion includes such topics as increased life expectancy, post-retirement expectations and the limits on post-retirement resources. ...
Miscellaneous severed letter
6 July 1989 Income Tax Severed Letter 7-4076
July 6, 1989 # 287 MISSISSAUGA DISTRICT OFFICE HEAD OFFICE A Appeals Division Resource Industries 5 West Section Allan B. ... Section Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate ...
Miscellaneous severed letter
1 November 1991 Income Tax Severed Letter 91M11254 F - Net Profit Interests and Production Royalty
1 November 1991 Income Tax Severed Letter 91M11254 F- Net Profit Interests and Production Royalty Unedited CRA Tags ITR 1206(1) QUESTION 27. Net profits interests ("NPI") have usually been treated as resource royalties by Revenue Canada. ... ANSWER 27. The Department would consider the NPI to be a production royalty where the recipient of the NPI (the "taxpayer") has a Crown royalty (in respect of subparagraph (a)(i) or (ii) of the definition of production royalty in subsection 1206(1) of the Regulations) and it is reasonable to consider that the taxpayer would have had the Crown royalty if the taxpayer's only source of income had been the NPI. ...
Miscellaneous severed letter
16 September 1994 Income Tax Severed Letter 9419566 - Youth Service Canada
We also refer to our meeting of September 12, 1994, with Pierre Paquette and Allan MacDonald of your division and Human Resources Development Canada officials. Our understanding of the relevant facts is as follows: • Youth Service Canada (the Program) is a program under the Youth Employment and Learning Strategy and administered by Human Resources Development Canada (HRD). • The Program, as announced in a Government of Canada news release on April 15, 1994, is described as a program which “will enable young people to gain meaningful work experience, while using and improving their personal and work-related skills, through community service projects.” • Each project, lasting from six to nine months, will involve 10 to 20 out-of-school, unemployed young people between the ages 18 and 24. ... The participant recognizes that his/her participation in the project a) is subject to his/her eligibility status being certified by Human Resources Development Canada (HRD), and b) can be terminated at any time by the coordinator at his/her discretion. 2. ...
Miscellaneous severed letter
20 June 1988 Income Tax Severed Letter 5-5797 - [Minimum Tax]
20 June 1988 Income Tax Severed Letter 5-5797- [Minimum Tax] DATE June 20, 1988 To Current Amendments & Regulations Division Mr. John Shaw FROM Bilingual Services and Resource Industries Division C. ...
Miscellaneous severed letter
10 April 1985 Income Tax Severed Letter
10 April 1985 Income Tax Severed Letter DATE April 10, 1985 To- APPEALS BRANCH Appeals & Referrals Division FROM- RESOURCES INDUSTRIES SECTION G.R. ...