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Administrative Letter

7 January 1992 Administrative Letter 9134186 F - Maintenance Payments Adult Child Third Parties

2.      Do payments made to a child subsequent to reaching the age of majority qualify as maintenance payments considering the requirements of 24(1) law? ... Despite the absence of specific comments in IT-118R3 it remains our position that a payment made for the benefit of a child in the custody of the spouse would include a payment made directly to the child and would qualify for a deduction as long as the payment was made at the discretion of the spouse and otherwise met the criteria set out in paragraphs 60(b),(c) or (c.1). 2.       ...
Administrative Letter

28 September 1989 Administrative Letter 73966 F - Disability Tax Credit

The credit will be available for 1988. 2.     The disability begins in May 1988 and ends in January 1989.  ... 2.     An individual is involved in a serious automobile accident in November 1988 which leaves him/her comatose, with no expectation of recovery, as he/she is being kept alive by machines.  ... The child would qualify if, when the impairment was diagnosed, it was reasonably expected to last for a continuous period of at least 12 months. 2.      ...
Administrative Letter

21 September 1993 Administrative Letter 9326106 F - Foreign Tax Credit - Can Resident U.S. Citizen (4093-U5)

Tax 2.     U.S. Sourced Income Dividend Income Interest Income Taxable Capital Gain XXXXXXXXXX Other Income Total U.S. ... In order to determine the taxes for which Canada should grant a FTC, it is necessary to determine each source of income from the United States as in 2 above and determine whether the United States would have the right to tax such source of income if the resident of Canada were not a U.S. citizen and at what rate. In accordance with paragraph 2 of Article XXIX (subject to paragraph 3) of the Convention the United States is permitted to tax its citizens as if there were no convention between Canada and the United States. ...
Administrative Letter

1993 Administrative Letter 9335986 F - Partnership - Specified Member

As stated in paragraph 2 of Interpretation Bulletin IT-90, a partnership is the relation that subsists between persons carrying on business in common with a view to profit. That statement is in conformity with the Common Law definition of a partnership (e.g. section 2 of the Ontario's Partnership Act). ... 2)     Where the partnership engages others to carry out activities of the partnership (such as research), are the activities which relate to management, decision making, direction, promotion, etc., performed by the partner himself? ...
Administrative Letter

1 October 1990 Administrative Letter 901836 F - Charitable Organization Status - Trust Whose Income is Exempt in the Hands of Beneficiaries under Tax Treaty

2.     Could the Trust qualify as a "charitable organization" for purposes of paragraph 1 of Article 21? ... This is also confirmed by the Technical Explanation of paragraph 1 of Article XXI of the Convention. 2.      ... Generally, there are considered to be four principal types of charitable trusts, namely: 1)     trusts for the relief of poverty; 2)     trusts for the advancement of education; 3)     trusts for the advancement of religion; and 4)     trusts for other purposes beneficial to the community. ...
Administrative Letter

26 November 1991 Administrative Letter 913046 F - Income Deferral From The Destruction Of Livestock

Issue #l 24(1) Our Comments As outlined in paragraph 2 of Interpretation Bulletin IT-427, dated March 5, 1979, "livestock includes any and all animals (ie living organisms which are not plants or bacteria) if they are kept by man and are maintained and bred under controlled conditions for profit. ... Issue #2 Does the definition of "breeding animals" in subsection 80.3(1) of the Act  include  24(1) Our Comments The definition of "breeding animals" in subsection 80.3(1) of the Act is restricted to the animals listed in paragraphs 80.3(1)(a) and (b) of the Act. ... Paragraphs 2 and 3 of Interpretation Bulletin IT-206R, dated October 29, 1979 outlines the Department's general position on the issue of simultaneous business operations.  ...
Administrative Letter

29 July 2011 Administrative Letter 2011-0414631E2 - Overdue Advance Income Tax Ruling Fees

./96-188, s. 2 def. of "due date". Principal Issues: When are advance income tax ruling fees due? ... Under the definition of "due date" in section 2 of the Interest and Administrative Charges Regulation, the due date, unless provided for otherwise, is 30 days after the day on which a demand for payment is issued. ...
Administrative Letter

29 July 2011 Administrative Letter 2011-0414681E2 - Overdue Advance Income Tax Ruling Fees

./96-188, s. 2 def. of "due date". Principal Issues: When are advance income tax ruling fees due? ... Under the definition of "due date" in section 2 of the Interest and Administrative Charges Regulation, the due date, unless provided for otherwise, is 30 days after the day on which a demand for payment is issued. ...
Administrative Letter

29 July 2011 Administrative Letter 2011-0414641E2 - Overdue Advance Income Tax Ruling Fees

./96-188, s. 2 def. of "due date". Principal Issues: When are advance income tax ruling fees due? ... Under the definition of "due date" in section 2 of the Interest and Administrative Charges Regulation, the due date, unless provided for otherwise, is 30 days after the day on which a demand for payment is issued. ...
Administrative Letter

29 July 2011 Administrative Letter 2011-0414601E2 - Overdue Advance Income Tax Ruling Fees

./96-188, s. 2 def. of "due date". Principal Issues: When are advance income tax ruling fees due? ... Under the definition of "due date" in section 2 of the Interest and Administrative Charges Regulation, the due date, unless provided for otherwise, is 30 days after the day on which a demand for payment is issued. ...

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