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Technical Interpretation - Internal summary
13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices -- summary under Subparagraph 6(1)(a)(i)
. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...
Technical Interpretation - Internal summary
23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization -- summary under Paragraph 149(1)(l)
" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...
Technical Interpretation - Internal summary
21 January 2013 Internal T.I. 2012-0442021I7 F - Assessing 163(2) penalty -- summary under Subparagraph 163(2)(a)(i)
. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...
Technical Interpretation - Internal summary
15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement -- summary under Eligible Relocation
. … ...
Technical Interpretation - Internal summary
24 December 2015 Internal T.I. 2014-0560831I7 - International shipping -- summary under Paragraph 81(1)(c)
. … [T]he Taxpayer would need to demonstrate that the ship owner is operating the ship under the Taxpayer’s direction and not, in effect, under the direction of the Related Party Customers. ...
Technical Interpretation - Internal summary
9 May 2011 Internal T.I. 2011-0399531I7 F - Computation of safe income -- summary under Paragraph 55(2.1)(c)
. … The CRA's longstanding position is instead to reduce the safe income on hand by every dollar of expenses that contributed to the loss sustained by the corporation on the grounds that such income is no longer on hand to contribute to the unrealized capital gain on a share. ...
Technical Interpretation - Internal summary
9 June 2011 Internal T.I. 2011-0395001I7 F - Co-propriété indivise d'un duplex -- summary under Ownership
. … In the case where each of the co-owners has the exclusive right to live in his or her own unit, the value of their undivided share must take into account at the same time the exercise by each of them of the exclusive use and enjoyment of their unit, which necessarily includes the right to the use of the common parts of the building, and the prohibition on the use of the unit occupied by the other co-owner. ...
Technical Interpretation - Internal summary
16 December 2010 Internal T.I. 2010-0380461I7 F - Cotisations versées à régime d'assurance-salaire -- summary under Subparagraph 6(1)(f)(v)
. … [W]here a trustee or an insurance company pays benefits to an employee from a wage-loss replacement plan over which the employer does not exercise control, or where the employer does not determine eligibility for benefits, the trustee or insurance company is required to report the benefit amounts on a T4A information slip. ...
Technical Interpretation - Internal summary
1 April 2010 Internal T.I. 2009-0352611I7 F - Redressement après le délai de prescription -- summary under Subparagraph 152(4)(a)(i)
1 April 2010 Internal T.I. 2009-0352611I7 F- Redressement après le délai de prescription-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) statement of incorrect income amount for spouse for s. 118(1)(a) credit purposes is a misrepresentation – but CRA must establish that prudent person would not have so erred Where a taxpayer claimed the married or common-law partnership tax credit (the "Tax Credit") and, after the taxpayer’s spouse was assessed beyond the normal reassessment period to add unreported income, can CRA also reassess the taxpayer beyond the normal reassessment period? ...
Technical Interpretation - Internal summary
12 January 2011 Internal T.I. 2010-0375801I7 F - Bien agricole admissible détenu avant 1987 -- summary under Subparagraph 110.6(1.3)(c)(ii)
The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...