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Miscellaneous severed letter

4 June 1990 Income Tax Severed Letter ACC9597 - Deductibility of Prepayment Penalty Incurred in Repaying Debt

Olympia floor & Wall Tile v. M.N.R. [[1970] C.T.C. 99] 70 DTC 6085 24(1) 23 We see no competition between equally applicable provisions of the law in the other two cases. ...
Miscellaneous severed letter

22 November 1989 Income Tax Severed Letter 7-4234 - [N/A]

Liebig & Co. v. Leading Investments Ltd. (1980) (25 D.L.R. (4th) 161) as support for the position that a real estate commission is not receiveable under paragraph 12(1)(b) with respect to an unclosed sale. ...
Miscellaneous severed letter

19 June 1989 Income Tax Severed Letter 5-7673 - [Subsection 55(2) of the Act]

Gain 200,000- less Tax @ 485 (96,000)- Net Increase in Safe Income $204,000 204,000 Safe Income on Hand immediately after disposition of SRTC property $5,404,000 ...
Miscellaneous severed letter

4 June 1992 Income Tax Severed Letter 9207465 - Gifts of Residual Interest

" In ascertaining the residual value, one would determine what an arm's length person would pay today in order to have the capital of the trust "x" years from now. ...
Miscellaneous severed letter

10 December 1992 Income Tax Severed Letter 9209525 - Overeseas Employment Tax Credit

> 90%) of his duties of employment in Country P 6. Individual Y is in Country P to carry out the following activities: (a) To conclude a joint venture contract with a resident of Country P. ...
Miscellaneous severed letter

14 December 1992 Income Tax Severed Letter 9224406 - Benefits Paid from and EBP to a Non-resident

We note that the Federal Court of Appeal [[1992] 2 C.T.C. 379] (92 DTC 6473) did not deal with whether the stock option benefit was "remuneration " for purposes of the Canada-U.K. ...
Miscellaneous severed letter

2 September 1992 Income Tax Severed Letter 9210595 - Education Tax Credit

Subsection 118.6(2) of the Act reads, in part, as follows: Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information "For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted an amount determined by the formula A x $60 x B (...)" ...
Miscellaneous severed letter

23 November 1992 Income Tax Severed Letter 9234525 - Class 12(1)(s) - Point-of-Sale Equipment

Subparagraph (iv) goes on to read "... and all or substantially all the use of which is in conjunction with that property. ...
Miscellaneous severed letter

4 August 1992 Income Tax Severed Letter 9215095 - Minimum Tax and Payment Out of DPSP

., (B) all amounts each of which was included in computing the individual's income for the year and is a single payment out of or under a deferred profit sharing plan, a superannuation or pension fund or plan or a foreign retirement arrangement (I) as a consequence of the death, withdrawal from the fund, plan or arrangement or termination of employment of a person, (...)" ...
Miscellaneous severed letter

12 June 1992 Income Tax Severed Letter 9216415 - Take-or-pay Amount - Advance - Large Corporation Tax

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

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