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Miscellaneous severed letter
21 August 1989 Income Tax Severed Letter 7-4236 - Security lending arrangements
We also refer to Olympia & York Developments Ltd. v The Queen, [[1980] C.T.C. 265] 80 DTC 6184(FCTB), at p. 6193. ...
Miscellaneous severed letter
25 March 1992 Income Tax Severed Letter 9205155 - Housing loan to sole shareholder-employee with no interest or repayment terms
In the 1988 Revenue Canada Round Table, we set out the following position: " Where a public corporation makes a bona fide loan to a shareholder qua employee rather than qua shareholder, on the same conditions as to other employees who are not shareholders, it is Revenue Canada's policy to treat it as a loan to an employee rather than to a shareholder (Ref. ...
Miscellaneous severed letter
31 January 1992 Income Tax Severed Letter 9135055 - Charitable donations by part-year resident
XXX = 89%- see paragraph's 5 and 17 of Interpretation Bulletin IT- 171R) and therefore former section 118.91 would have denied a nonrefundable tax credit otherwise allowable under section 118.1 except where the non-refundable tax credit otherwise permitted may reasonably be considered wholly applicable to the individual for the period or periods in the year throughout which he is resident in Canada, employed in Canada or carrying on business in Canada. ...
Miscellaneous severed letter
13 March 1992 Income Tax Severed Letter 9204165 - Provincial sales tax reassessment
Phil Keirstead Business & General Business Enquiries Division Audit Review (148-1-6) H. ...
Miscellaneous severed letter
14 April 1992 Income Tax Severed Letter 9201275 - Social assistance and partnerships
Although subsection 96(1) of the Act sets out rules for the computation of a partner's income "... as if the partnership were another person.. ...
Miscellaneous severed letter
12 June 1992 Income Tax Severed Letter 9216605 - Resource industry farmout transactions
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. ...
Miscellaneous severed letter
28 July 1987 Income Tax Severed Letter 5-3485 - Interpretation of the words “licence to use” found in the definition of “computer software” in subsection 1104(2) of the Income Tax Regulations
Saint John Shipbuilding & Dry Dock Co. Ltd. [[1980] C.T.C. 352] 80 DTC 6273. ...
Miscellaneous severed letter
Income Tax Severed Letter AC58553F F
Pour la directrice Division des services bilingues et des industries d'exploitation des ressources Direction des décisions ` Document Disclosed Pursuant to the Access to Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...
Miscellaneous severed letter
25 February 1998 Income Tax Severed Letter 9802265 - Deferred salary leave plan
The plan must provide that the salary deferred by the participant in a taxation year, as stipulated under Article 23.01(e), does not exceed 33 1/3 % of the participant's regular annual salary and any related benefit. 3. ...
Miscellaneous severed letter
9 October 1996 Income Tax Severed Letter 9617995 F - Fiducie de protection d'actifs
OPINION JURIDIQUE: N/A RGAE: N/A OPINION DE FINANCE: N/A RÉVISION: N/A JURISPRUDENCE: N/A PUBLICATIONS DE RCI: ENTETE "DOCUMENT KEY": 5 ENTETE "DATABASE": 1 ENTETE LIGNE SUJET: Papillon et fiducie de protection d'actifs DOSSIER SUJET: HAA: 5102-3-1 Samson Bélair Deloitte & Touche Comptables agréés 5-961799 4 Place Laval, bureau 500 Robert Gagnon Laval (Québec) H7N 5Y3 A l'attention de M. ...