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Miscellaneous severed letter
24 May 1983 Income Tax Severed Letter A-8029 F - [Régime de conversion industrielle]
Le paiement maximum des suppléments de transition est de 480 $. 6. Allocation de ré-intégration---------------------------- Un employé est éligible à cette allocation lorsque ses prestations de l'assurance-chômage sont terminées et qu'il a été incapable de se trouver un nouveau travail soit à cause de son âge, de sa santé, de son éducation ou toute autre raison valable. ...
Miscellaneous severed letter
13 December 1983 Income Tax Severed Letter
The "cost amount" to the trust of the trust property so distributed will be determined as if the trust were a resident of Canada $7,500 (ii) Under paragraph 107 (2)(b), your client acquires the property at a cost, which is (A) the "cost amount" of the property to the trust $ 7,500 plus (B) the Adjusted cost base of your client's capital interest as at January 1, 1983 $6,600 less the "cost amount of his capital interest" (as defined in paragraph 108(1)(d)) $(7,500)_______ Excess of (A) over (B) NIL______ Cost of acquisition of property to your client $7,500______ (iii) Under paragraph 107 (2)(c), your client disposes of his capital interest for proceeds equal to (ii) above $7,500______ For the purpose of computing your client's taxable capital gain (if any) paragraph 107(1)(a) determines the Adjusted cost base of his interest to be the greater of the: Adjusted cost base of the interest (i.e. $6,600) and the "cost amount of his capital interest" (as calculated in paragraph 108(1)(d)) (i.e. $7,500). ...
Miscellaneous severed letter
27 September 1985 Income Tax Severed Letter B-6292 - [Paragraphs 8(1)(f) and (h)]
Quoting from the latter judgment the Court said, "... what was said in Cival regarding the nature of the contractual relationship which is necessary to allow a taxpayer to claim deductions is equally applicable to both paragraphs 8(1)(f) and 8(1)(h). ...
Miscellaneous severed letter
9 December 1981 Income Tax Severed Letter
Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch ...
Miscellaneous severed letter
5 September 1990 Income Tax Severed Letter ACC9728 - Canadian Investment Income
McCarron-McCuire LONDON DISTRICT OFFICE 17 (613) 957-2092 Attention: Brian Deacon Large Files FILE 901336 SUBJECT: 24(1) the "taxpayer" "Canadian investment income " We are writing in response to your memorandum dated June 5, 1990, regarding the method of calculating the "Canadian investment income", as defined in paragraph 129(4) (a) of the Income Tax Act (the "Act"), of the taxpayer. ...
Miscellaneous severed letter
29 June 1989 Income Tax Severed Letter AC57461 F - Crédit pour la recherche scientifique et le développement expérimental accordés par le Québec
Dans le dictionnaire Law & Commercial Dictionary de West's ce terme est défini comme étant: "In contract, the benefit or advantage which the promisor is to receive from a contract is the inducement for making it. ...
Miscellaneous severed letter
16 December 1988 Income Tax Severed Letter 7-3381 - [IT-96R4, paragraphs 1 and 2 (allocation of issue price between debentures and warrants) IT-114, paragraphs 3 and 24 (deductibility of discount considered to be the equivalent of interest)]
A/Chief Leasing & Financing Section Financial Industries Division Rulings Directorate ...
Miscellaneous severed letter
18 April 1990 Income Tax Severed Letter AC59665 - Butterfly Reorganizations - Exception to Deemed Capital Gain Provision
In determining whether or not the requirements of paragraph 55(3)(b) of the Act are satisfied in a particular situation, transactions occurring before and after the transfer of property referred to in that paragraph which are "in the course of " the "reorganization" referred to therein will have to be considered. ...
Miscellaneous severed letter
1 June 1990 Income Tax Severed Letter ACC9059 - Inventory Considered Depreciable Property
As requested, we are returning your materials with this memorandum. for Chief Leasing & Financing Section Rulings Directorate ...
Miscellaneous severed letter
28 September 1990 Income Tax Severed Letter AC74385 - Requirements for Deductibility of Damages
" 24(1) A/Director Bilingual Services & Resource Industries Division Rulings Directorate ...