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Folio Summary

S6-F1-C1 - Residence of a Trust or Estate -- summary under Subsection 2(1)

S6-F1-C1- Residence of a Trust or Estate-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) 1.2... ...
Folio Summary

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime -- summary under Subsection 5(1)

The Queen, [1990] 2 CTC 439, 90 DTC 6662, payments of strike pay were held not to be income from a source. ...
Folio Summary

S5-F1-C1 - Determining an Individual’s Residence Status -- summary under Subsection 2(1)

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) 1.10 The most important factor to be considered in determining whether an individual leaving Canada remains resident in Canada for tax purposes is whether the individual maintains residential ties with Canada while abroad…. 1.12 Where an individual who leaves Canada keeps a dwelling place in Canada (whether owned or leased), available for his or her occupation, that dwelling place will be considered to be a significant residential tie with Canada during the individual's stay abroad. ...
Folio Summary

S1-F3-C4 - Moving Expenses -- summary under

The notion of ordinarily resided must be given the meaning assigned... in Thomson v Minister of National Revenue, [1946] S.C.R. 209, 2 DTC 812. 4.12 For details regarding individuals who are absent from but resident in Canada for the purposes of the Act, see Income Tax Folio S5-F1-C1, in particular ¶1.10- 1.21.... ...
Folio Summary

S4-F16-C1 - What is a Partnership? -- summary under Section 96

Canada, [1998] 2 S.C.R. 298, 98 DTC 6505, and later in Backman v. Canada, [2001] 1 S.C.R. 367, 2001 DTC 5149, and Spire Freezers Ltd. v. ...
Folio Summary

S4-F7-C1 - Amalgamations of Canadian Corporations -- summary under Paragraph 87(2)(a)

Consequently, transactions that occur sequentially on the same day but prior to the amalgamation will be reported by the predecessor corporation in the tax year that is deemed to have ended immediately before the amalgamation. 1.17 …Where the duration of…short tax years of the predecessor corporations would be a matter of days, for instance where the normal tax year-ends are December 31 and the amalgamation takes place on January 2, and where there would be adverse implications in having short tax years, consideration should be given to requesting the Minister's concurrence to extend such year-ends…. ...
Article Summary

Chris Lang, "Debt Restructuring Using a Reverse Vesting Order: Tax Issues", Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2 -- summary under Subsection 80(13)

Chris Lang, "Debt Restructuring Using a Reverse Vesting Order: Tax Issues", Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2-- summary under Subsection 80(13) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(13) Overview of Delta 9 (p. 2) In Delta 9, a licensed producer of cannabis (the target corporation) had entered CCAA proceedings. ...
Article Summary

Dunn, Nielsen, "Exchanges of Property for Shares: section 85-Part 2", 1995 Canadian Tax Journal, Vol. 43, No. 2, p. 496. -- summary under Subsection 85(1)

Dunn, Nielsen, "Exchanges of Property for Shares: section 85-Part 2", 1995 Canadian Tax Journal, Vol. 43, No. 2, p. 496.-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) ...
Article Summary

Perry Truster, "Taxable Benefits: How Much is Taxable?", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2 -- summary under Subsection 15(1)

", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) ABC Steel (p.2) In ABC Steel (74 DTC 1124(TRB))…a shareholder leased property to a corporation. ...
Article Summary

Cynthia Morin, Suhaylah Sequeira, "Withholding Tax Obligations: Proposed Amendments to Subsections 212(13.1) and 212(13.2)", International Tax Highlights, Vol. 1, No. 2 November 2022, p. 2 -- summary under Subsection 212(13.2)

Cynthia Morin, Suhaylah Sequeira, "Withholding Tax Obligations: Proposed Amendments to Subsections 212(13.1) and 212(13.2)", International Tax Highlights, Vol. 1, No. 2 November 2022, p. 2-- summary under Subsection 212(13.2) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(13.2) Current s. 212(13.2) rule The existing s. 212(13.2) rule applies Part XIII tax to a payment made by a non-resident person to another non-resident person that is deducted from the payer’s taxable income earned in Canada. ...

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