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Technical Interpretation - Internal summary
8 September 2023 Internal T.I. 2023-0987091I7 - Trailing Commissions and Dealer Rebates -- summary under Subsection 12(2.1)
., until May 31, 2025) exemption to a ban (imposed effective June 1, 2022) on OEO Dealers from being paid trailer fees by a mutual fund or its manager, to receive a trailing commission from the mutual fund or dealer in order to facilitate the OEO Dealer paying a rebate of such amount to its clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances … it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...
Technical Interpretation - Internal summary
8 September 2023 Internal T.I. 2023-0987091I7 - Trailing Commissions and Dealer Rebates -- summary under Paragraph 12(1)(x)
., until May 31, 2025) from this prohibition in order to facilitate the OEO Dealer in paying a rebate of such amounts to their clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances … it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...
Technical Interpretation - External summary
21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA -- summary under Subsection 13(1)
., the actual capital cost grossed-up to $15,000,000 and multiplied by the 50% Class 43.2 rate); It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund; It claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate); It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. In 2025, the capital cost of the property will have been reduced (pursuant to s. 13(7.1)(e)) by the two federal tax credits claimed and (pursuant to s. 13(7)(f)) by the NS CITC “assistance” claimed, i.e., to $4,500.000. ...