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Ministerial Letter
26 February 1999 Ministerial Letter 9903518 - TAXABLE CANADIAN PROPERTY - EMIGRATION
The Department of Finance responded to those recommendations on October 2, 1996, by announcing changes to the Act that would be effective as of that date. ... These proposals are based on the changes announced on October 2, 1996, and are designed to enhance Canada’s ability to tax emigrants’ Canadian-source gains. ...
Ministerial Letter
24 September 1999 Ministerial Letter 9920568 - AUTOMOBILE TAXABLE BENEFITS
In general, this standby charge is 2 per cent per month of the cost of the automobile or two-thirds of the lease costs calculated with reference to the number of days the automobile was available to the employee or to a person related to the employee. ... Yours sincerely, Bill McCloskey Assistant Deputy Minister Policy and Legislation Branch David Shugar 957-2133 September 17, 1999- 2- ...
Ministerial Letter
11 March 1999 Ministerial Letter 9903988 - DEPARTING CANADA WITH TCP
The Department of Finance responded to those recommendations on October 2, 1996, by announcing draft amendments to the Income Tax Act, which, when enacted, will be effective as of that date. ... On December 23, 1998, the Honourable Paul Martin, Minister of Finance, released detailed proposals to implement the draft amendments announced on October 2, 1996. ...
Ministerial Letter
20 August 1990 Ministerial Letter 900538 F - NR4B Guide and Forms
Accordingly, we suggest that line 2 under Exemption Code "G" be reworded to read "...in respect of the production or reproduction of any literary, dramatic, musical or artistic work (except...". 2. In connection with this point, we offer the following comments concerning payments for computer software programs which may help to explain the exemption provided under subparagraph 212(1)(d)(vi)of the Act. ...
Ministerial Letter
4 July 1989 Ministerial Letter 58088 F - Qualified Small Business Corporation Shares
2) Does the policy as stated in the answer to question 51 of the 1986 Conference Report Round Table remain in effect? ... As such, provided the other requirements in the definition of QSBCS in subsection 110.6(1) are met, the shares of Holdco will be considered to be QSBCS's. 2) Our policy as stated in the answer to question 51 of the 1986 Conference Report Round Table remains in effect. ...
Ministerial Letter
28 May 1990 Ministerial Letter 59378 F - Investment Tax Credit
The hypothetical situation outlined in your letter was as follows: 1) Company A carried out scientific research and experimental development ("SR & ED") with a view to creating a product which is unrelated to its existing business. 2) Mr. ... 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? ...
Ministerial Letter
31 July 1990 Ministerial Letter 59818 F - Associated Corporations
X is an individual who owns all of its issued and outstanding shares. 2. ... Based on the information provided and our assumptions the four corporations are associated for their 1989 taxation years for the following reasons. (1) Aco and Bco are associated by virtue of paragraph 256(1)(a) of the Act, (2) Aco and Dco are associated by paragraph 256(1)(b) by virtue of subparagraphs 256(1.2)(f)(iv) and 256(1.2)(c)(i) of the Act. (3) Dco and Cco are associated by the provisions of paragraph 256(1)(c) of the Act. ...
Ministerial Letter
15 November 1989 Ministerial Letter 58938 F - Meaning of "On the Winding-up" - "Wound Up"
A and B are companies incorporated under the laws of the Province of British Columbia. 2. ... Astaphan in a telephone conversation on November 2, 1989 ((19(1)/Astaphan), the Department's views as to when a corporation is considered to have been wound-up are described in IT-126R2, particularly in paragraphs 3 to 5 thereof. ...
Ministerial Letter
1 November 1989 Ministerial Letter 58368 - Rachat d'actions - Dividende présumé réputé être gain en capital
Une corporation transfère un bien à une corporation qui lui est liée en se prévalant des dispositions de l'article 85 (L.I.R.). 2. ... Le dividende est reçu par une corporation résidant au Canada. 2. Le dividende est imposable et a donné droit à une déduction en vertu du paragraphe 112((1) ou 138(6) LIR. 3. ...
Ministerial Letter
6 February 1990 Ministerial Letter 59398 F - Associated Corporations - Acquisition of Control
Holdco's assets consist of shares in other companies, including a wholly-owned subsidiary with accumulated losses. 2. ... B have acquired the necessary number of shares to control Holdco. 2. ...