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Ministerial Correspondence
22 November 1990 Ministerial Correspondence 73984 F - CCA Class on Railway Tracks and Spur Line
BACKGROUND 1. 24(1) 2. 3. 4. Class 10 Schedule II of the Regulations Class 10 in Schedule II of the Regulations provides for: Property not included in any other class that is (k) property (other than property included in Class 28 or property described in paragraph (l) or (m)) that was acquired for the purpose of gaining or producing income from a mine and that is (i) a structure that would otherwise be included in Class 8, or (ii) machinery or equipment,...; (l) property acquired after the 1971 taxation year for the purpose of gaining or producing income from a mine and providing services to the mine or to a community where a substantial proportion of the persons who ordinarily work at the mine reside, if such property is... ... Our position was confirmed by Current Amendments and Regulations Division on January 9, 1989. ... Consequently, since the 24(1) A. Class 10(k) You asked whether railway track used by mining companies for the purpose of gaining or producing income from a mine can also be considered as Class 10(k) property. ...
Ministerial Correspondence
28 October 2011 Ministerial Correspondence 2011-0421401M4 - children's arts tax credit
Such activities fall under the categories: * literary arts * visual arts * performing arts * music * media * language * customs * heritage * wilderness * natural environment Developmental activities include activities that help children develop and use particular skills and activities with structured interaction among children in which supervisors teach, tutor, enrich academic subjects, or help children develop interpersonal skills. ... To be eligible, an activity must: * be supervised; * be suitable for children; and * contribute to the development of creative skills or expertise in an artistic or cultural activity. Generally, an eligible program (which does not include those that are part of a school curriculum) includes: * a weekly program of at least eight consecutive weeks with a minimum of 90% of the activities eligible; * a program of five or more consecutive days of which more than 50% of the daily activities are eligible; or * a weekly program of at least eight consecutive weeks where a child can select among a variety of activities if more than 50% of the activities offered are eligible or if more than 50% of the time is scheduled for eligible activities. ...
Ministerial Correspondence
2 July 1990 Ministerial Correspondence 9015214 F - Remission Request
2 July 1990 Ministerial Correspondence 9015214 F- Remission Request Unedited CRA Tags n/a July 2, 1990 TORONTO DISTRICT OFFICE HEAD OFFICE Pierre St. Laurent Technical Review Section Director- Taxation Technical Publications Division Gary Donell Tel. (613) 957-9231 Case 782 File 4-901521 EACC9385 SUBJECT: Remission Request 19(1) Our Minister, the Honourable Otto Jelinek, has received a letter dated June 20, 1990 from 19(1) requesting a remission of taxes and related interest for the 1984 and 1985 statute barred years and a remission of a late filing penalty assessed for the 1984 year. ...
Ministerial Correspondence
27 April 1990 Ministerial Correspondence 74554 - Déduction pour amortissement - Frais engagés pour acquérir servitude de passage
Ainsi, au paragraphe 29 du Bulletin d'interprétation IT-143R2 du 10 août 1983, il est mentionné que: 29. ... Défrichage ou nivellement de terrains Le défrichage ou le nivellement de terrains comprend notamment l'enlèvement d'arbustes, d'arbres, de racines, de pierres, ainsi que le premier labourage destiné rendre la terre productive. ... Dans la mesure où vous avez effectivement payé ces frais, vous pouvez • déduire une partie du paiement dans l'année où les frais ont été payés et • reporter le reste du paiement une année ultérieure. ...
Ministerial Correspondence
21 November 1990 Ministerial Correspondence 900714 F - Forfeiture of Pay under R.C.M.P Act
21 November 1990 Ministerial Correspondence 900714 F- Forfeiture of Pay under R.C.M.P Act Unedited CRA Tags n/a 90071-4 November 21, 1990 S. Short Personal & General Issue 1. Whether a "forfeiture of pay" under subsection 45.12(3) of the Royal Canadian Mounted Police Act, R.S.C. 1985, c. ...
Ministerial Correspondence
9 August 1990 Ministerial Correspondence 74794 F - Manufacturing and Processing Deductions - Qualified Activities
" Two court cases which do not support our position and were heard together at the Federal Court of Appeal on April 10, 1990 are.The Queen v. ... However, pursuant to your request, but without having reviewed the contracts entered into we have stated our opinion based on the information provided. In some situations 24(1) D) Used primarily Paragraph 16 of IT-331R provides comments on a piece of equipment used in carrying out both a designated and non-designated purpose or activity. ...
Ministerial Correspondence
5 March 1990 Ministerial Correspondence 59114 F - Qualifying Small Business Corporation Assets
You have provided us with the following hypothetical situation: 1. A company uses 40% of its assets in an active business in Canada. 2. ... As set out below, there are greater than five employees employed directly in the operation and maintenance of the five apartment buildings: a) one full-time manager per building (5), b) one property manager, c) one maintenance man/painter, and d) one accountant. 4. ...
Ministerial Correspondence
16 August 1989 Ministerial Correspondence 73804 F - Capital v. Income - IT-182
Income- IT-182 Unedited CRA Tags n/a August 16, 1989 Winnipeg District Office Head Office Specialty Rulings Directorate K.E. ... For example, amounts totalling 24(1) #106, 107 & 114) would appear to be income subsidies or expense reimbursements. ... (d) Eligible capital amounts This category relates to all other payments of a capital nature that cannot be included in either (a), (b) or (c) and relate to the business of the taxpayer. ...
Ministerial Correspondence
1 June 1990 Ministerial Correspondence 74624 F - Non-resident Tax for Visiting Teachers and Professors
(i) Finland Treaty Article XI of the Canada-Finland Treaty is very similar to Article VIIIA of the 1942 Canada-U.S. ... (ii) Norway and Trinidad & Tobago Treaties These treaties are very like the old Treaty considered by the Tax Appeal Board in Dorian Smith v. ... (iii) Ireland and Denmark Treaties These two treaties are quite different from the Treaties referred to above. ...
Ministerial Correspondence
19 November 1990 Ministerial Correspondence 902994 F - Meaning of "Specified Non-resident Shareholder"
19 November 1990 Ministerial Correspondence 902994 F- Meaning of "Specified Non-resident Shareholder" Unedited CRA Tags 18(4), 256(6) 902994 G. Middleton (613) 957-2127 Dear Sirs: Re: Subsection 18(4) This is in reply to your letter of October 18, 1990 concerning the application of subsection 18(4) of the Income Tax Act (the "Act") in the following situation: Facts 24(1) 24(1) For the purposes of subsection 18(4) of the Act, you have asked whether Usco qualifies as a "specified non-resident shareholder" of Canco as defined in subsection 18(5) of the Act. ...