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Technical Interpretation - Internal summary
27 January 2012 Internal T.I. 2011-0428831I7 F - Crédit d'impôt pour frais médicaux -- summary under Paragraph 118.2(3)(b)
. … [T]he taxpayer could claim the METC for the medical expenses incurred in 2007, 2008 and 2009 in that the taxpayer no longer has the right to be reimbursed for these expenses as part of the group drug insurance plan. ...
Technical Interpretation - Internal summary
19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules -- summary under Paragraph 110(1)(d)
A further situation discussed was where a trust is established by the employer to acquire and hold shares of the corporation for employees, but allocations among the employees are entirely at the discretion of the trustees – so that CRA would consider that there is no agreement to acquire the shares until such discretion is exercised. ...
Technical Interpretation - Internal summary
19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules -- summary under Subsection 7(2)
. … [S]ubsection 7(2) cannot apply any earlier than when a specific number of shares have been allocated to an identifiable employee pursuant to a legally binding agreement to issue or sell shares. ...
Technical Interpretation - Internal summary
9 June 2011 Internal T.I. 2011-0396721I7 F - Déduction - habitants de régions éloignées -- summary under Subsection 110.7(1)
. … [I]n the situation you described, an individual who resides in a prescribed northern or intermediate zone for a period of at least six months and who has a 35-day work cycle in the said zone followed by an 8-day leave in his other residence at XXXXXXXXXX would be entitled to the deduction provided for in section 110.7. ...
Technical Interpretation - Internal summary
7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Revising Claims
…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...
Technical Interpretation - Internal summary
6 April 2010 Internal T.I. 2009-0343091I7 F - Montant pour enfant -- summary under Paragraph 118(4)(b)
. … Since Mr. A and Ms. B lived in separate self-contained domestic establishments during the period of the year in which they lived apart, the concept of the same "self-contained domestic establishment" in 118(4)(b) does not restrict the right of Mr. ...
Technical Interpretation - Internal summary
30 September 2010 Internal T.I. 2010-0373901I7 F - Bigamie fiscale - transfert de biens au décès -- summary under Subparagraph 40(4)(b)(i)
30 September 2010 Internal T.I. 2010-0373901I7 F- Bigamie fiscale- transfert de biens au décès-- summary under Subparagraph 40(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(4)- Paragraph 40(4)(b)- Subparagraph 40(4)(b)(i) application of s. 40(4)(b)(i) by both surviving spouse re House A and surviving common-law partner re House B – but not for overlapping years The taxpayer lived with his spouse in Immovables A, but thereafter commenced to live separate and apart from her, but did not divorce from her, and instead lived in a conjugal relationship with another (a common-law partner) in Immovable B until his death. ...
Technical Interpretation - Internal summary
9 December 2010 Internal T.I. 2010-0371741I7 F - Automobiles mises à la disposition des employés -- summary under Automobile
In both of the situations described above, since the vehicles … are designed and constructed with more than three seating positions and are not similar to a van or pick-up truck, we are of the view- based on their use- that those vehicles are automobiles for the purposes of the Act. ...
Technical Interpretation - Internal summary
12 August 2010 Internal T.I. 2010-0356781I7 F - Allocation de retraite, indemnité 2091 C.c.Q. -- summary under Retiring Allowance
. … [I]n the majority of circumstances, the compensation paid by the employer under C.C.Q Article 2092. appears to be to compensate for a prejudice caused by the absence of notice. ...
Technical Interpretation - Internal summary
24 January 2011 Internal T.I. 2010-0390111I7 F - GRIP Computation and Taxable Income for M&P Credit -- summary under Subsection 89(7)
. … It is clear to us, having regard to the provisions of elements I and J of element B of the formula in the definition of GRIP, that the MPPD Amount for a taxation year is not taken into account for purposes of the calculations. ...