Search - 制暴无限杀机 下载

18 March 1983 Income Tax Severed Letter 5-0057- [(1) Gross & Net Royalty Trust/(2) Reporting of Resource Income and Allowances] DATE: March 18, 1983 TO- Corporate Rulings Division FROM- Audit Programs Division Estate and Trust Group T. ... Carsley RE: (1) Gross & Net Royalty Trust (2) Reporting of Resource Income and Allowances We refer to the attached memoranda at March 8 and 15 concerning resource income and resource allowance. ...

24 January 1990 Income Tax Severed Letter ACC8926- Canada-Portugal Reciprocal Air & Shipping Exemption B. Fioravanti (613) 957-2073 HBW 4290-1 19(1) January 24, 1990 Dear 19(1) Re: Canada- Portugal- Reciprocal Air & Shipping Exemption Your letter of January 9 together with enclosures has been referred to the attention of C. ...

22 November 1982 Income Tax Severed Letter RRRR63- Application of paragraph 95(2)(d) — merger of two United States foreign affiliates with United States parent who is a foreign affiliate Unedited CRA Tags 95(2)(d) XXX We reply to your letter dated August 10, 1982 wherein you request our opinion on the application of paragraph 95(2)(d) of the Income Tax Act in the case of a merger of two United States foreign affiliates with their United States parent who is also a foreign affiliate. ... We are pleased to advise that where there has been a bona fide merger of two United States foreign affiliates with their foreign affiliate United States parent paragraph 95(2)(d) of the Act will apply provided the other requirements of that paragraph are met viz "... and such merger is not as a result of the acquisition of property... ...

8 June 1987 Income Tax Severed Letter 7-1839- [Publication of Advance Income Tax Rulings # 3-0838] H.O. ... Brake June 8, 1987 Dear Sirs: Re: Publication of Advance Income Tax Rulings # 3-0838 Your letter of June 4, 1987 regarding the above-noted subject has been received and assigned to the Services, Public Utilities and Exempt Corporations Section for reply and may be identified by control number 7-1839. ...

12 December 1988 Income Tax Severed Letter 5-6777- [Scientific Research and Experimental Development ("SR & ED") "Non-Government Assistance"] M. Eisner (613) 957-2142 DEC 12 1988 Dear Sirs: Re: Scientific Research and Experimental Development ("SR & ED") "Non-Government Assistance" This is in reply to your letter of October 7, 1988 in which you asked us to reconsider a position set out in our letter to you dated September 28, 1988 wherein it was indicated that a taxpayer would not be entitled to an investment tax credit ("ITC") with respect to a reimbursement by virtue of paragraph 127(11.1)(c) of the Income Tax Act (the "Act"). This position was based on the concurrence that a reimbursement constituted non-government assistance as defined in subsection 127(9) of the Act in the following circumstances: a) A Canadian corporate taxpayer (Canco) incurs qualified SR & ED expenditures in Canada and owns all rights arising therefrom. b) A related non-resident corporation (NRCo) reimburses Canco for a portion of the qualified expenditures. ...

7 July 1991 Income Tax Severed Letter- Interest on loans — application of subparagraph 4(a) of Article 11 of the Canada-Netherlands Income Tax Convention Unedited CRA Tags 212(1)(b)(vii), Canada-Netherlands Income Tax Convension article 3, 11 Dear Sirs: This is in reply to your letter of May 8, 1991 in which you requested our views on the application of subparagraph 4(a) of Article 11 of the Canada-Netherlands Income Tax Convention (the "Convention"). ... The term "arm's length" is not defined in the Convention but paragraph 2 of Article 3 of the Convention provides that "... any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of the State concerning taxes to which the Convention applies. ... However, paragraph 251(1)(a) of the Act states that "... related persons shall be deemed not to deal with each other at arm's length". ...

1 February 1980 Income Tax Severed Letter 7-570- [] February 1, 1980 CALGARY DISTRICT OFFICE Chief of Audit Mr. ... Toyota (613) 995-1787 Section 125.1 Manufacturing & Processing Deduction ("MPD") This is in reply to your memorandum of January 10, 1980 requesting clarification of paragraph 34 of IT-145 as it relates to various items claimed by XXXX in determining its MPD in view of the St. ... Although fees paid for news services and talent fees (actors, etc.) may be related directly to qualified activities, they would not be included in the cost of M & P labour unless these functions were performed or normally performed by employees and the amounts are also included in the total cost of labour. ...

14 February 1980 Income Tax Severed Letter 7-598- [] February 14, 1980 HALIFAX DISTRICT OFFICE Chief of Audit J.R. ... Chief Services, Public Utilities, & Exempt Corporations Section Corporate Rulings Division Corporate Rulings Directorate Legislation Branch ...

20 February 1992 Income Tax Severed Letter 9202997- Registered retirement savings plan trust — death of annuitant Unedited CRA Tags 146(4), 146(1), 146(8.8), 104(13), 104(6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Duff Chief Rulings Directorate T3 Programs Section 957-8953 T2 & T3 Programs Division Attention: Aileen Wade 7- 920299 RRSP Trusts: Tax Reporting after Death of Annuitant This is in response to your memorandum of January 29, 1992 requesting that we review your proposed reply to XXX After reviewing the aforementioned draft we do not see any inaccuracies in it. ...

5 May 1992 Income Tax Severed Letter- Registered retirement savings plans — promotional activities by bank Unedited CRA Tags 146(2)(c.4) This is in reply to your memorandum of April 15, 1992, in which you ask us to review the letter of February 21, 1992, from the above-noted Bank concerning their promotional activities XXX. ... We therefore confirm our interpretations as contained in our previous correspondence noted above. for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch [SUBJECT: CAPITAL GAINS EXEMPTION & GAAR SECTION: 110.6(1), ...