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News of Note post
These are additions to our set of 1,632 full-text translations of French-language severed letters (mostly, Roundtable items and Technical Interpretations) of the Income Tax Rulings Directorate, which covers all of the last 13 ¾ years of releases of Interpretations by the Directorate. ...
News of Note post
These are additions to our set of 1,692 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ½ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,714 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ¾ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,838 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,849 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,859 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,890 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ¼ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,898 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...
News of Note post
These are additions to our set of 1,907 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...
News of Note post
Repairs or Running Expense Belgega-finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure- noted 9 June 2005 Internal T.I. 2005-0122511I7 F- Créance irrécouvrable dans une OSBL Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c)- Subparagraph 39(1)(c)(iv) loss on interest-bearing loan made by a director to an NPO qualified as BIL if NPO qualified as SBC Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) a debt obligation bearing a reasonable rate of interest satisfies s. 40(2)(g)(ii) 9 June 2005 External T.I. 2004-0097451E5 F- Régimes d'assurances collectives Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) employees can potentially pay top-up amounts for further benefits or receive taxable compensation for opting for lower benefits Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA criteria for determining whether there are 2 separate plans (one of which is fully employee-funded) 6 June 2005 External T.I. 2005-0114481E5 F- Division 149(1)o.2)(ii)(C) Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(B) deferred proceeds receivable for real estate sale do not qualify as real property Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(C) loan that funded rental property acquisition may still qualify after partial sale of portfolio/replacement borrowing can also qualify Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) loan that funded rental property acquisition may still qualify as “solely for the purpose of earning income” per s. 149(1)(o.2)(ii)(C) after partial sale of portfolio 9 June 2005 Internal T.I. 2005-0115481I7 F- Avantages imposables/voyages Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) since the particular shareholder-employees who benefited from trips provided by their employer’s supplier were known, the supplier should issue T4As to them Income Tax Regulations- Regulation 200- Subsection 200(2)- Paragraph 200(2)(g) T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers 9 June 2005 Internal T.I. 2005-0117851I7 F- Choix du paragraphe 14(1.01) de la Loi Income Tax Act- Section 14- Subsection 14(1.01) taxpayer could not make s. 14(1.01) election where "exempt gains balance" in respect of his business for the year is not nil 7 June 2005 External T.I. 2005-0121551E5 F- Déduction des intérêts- co-emprunteurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed from spouse under line of credit for income-producing purpose is deductible ...