Search - 制暴无限杀机 下载
Results 2171 - 2180 of 2491 for 制暴无限杀机 下载
Ruling
2012 Ruling 2012-0452401R3 - Payment to settle a liability for child support
Reasons: (1) & (2) The lump sum payment is not considered a qualifying "support amount" for purposes of paragraphs 56(1)(b) and 60(b) of the Act. ...
Ruling
2015 Ruling 2014-0536661R3 - Disposition of property by a foreign partnership
Definitions In this letter, unless otherwise stated, the following terms have the meaning specified below: (a) "adjusted cost base" " has the meaning assigned to that term in section 54 of the Act; (b) "Business" means the business of XXXXXXXXXX located adjacent to the Properties; (c) "Canco" means XXXXXXXXXX; (d) "capital property" has the meaning assigned to that term in section 54 of the Act; (e) "controlled foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (f) "Country X" means XXXXXXXXXX; (g) "CRA" means Canada Revenue Agency; (h) "designated liquidation and dissolution" has the meaning assigned to the term in subsection 95(1) of the Act; (i) "excluded property" has the meaning assigned to that term in subsection 95(1) of the Act; (j) "foreign accrual property income", also referred to herein as "FAPI", has the meaning assigned to that term in subsection 95(1) of the Act; (k) "foreign affiliate" has the meaning assigned to that term in subsection 95(1) of the Act; (l) "Foreign Corp" means XXXXXXXXXX; (m) "Foreign Holdco" means XXXXXXXXXX; (n) "Foreign LP" means XXXXXXXXXX; (o) "foreign resource property" has the meaning assigned to that term in subsection 66(15) of the Act; (p) "Foreign Subco1" means XXXXXXXXXX; (q) "Foreign Subco2" means XXXXXXXXXX; (r) "Foreign Subco3" means XXXXXXXXXX; (s) "Foreign Subco4" means XXXXXXXXXX; (t) "Mine 1" means XXXXXXXXXX located in XXXXXXXXXX; (u) "Mine 2" means XXXXXXXXXX located in XXXXXXXXXX; (v) XXXXXXXXXX; (w) "Parent" means XXXXXXXXXX; (x) "proceeds of disposition" has the meaning assigned to that term in section 54 of the Act; (y) "Properties" means Mine 1 and Mine 2, collectively; (z) "public corporation" has the meaning assigned to that term in subsection 89(1) of the Act; (aa) XXXXXXXXXX; (bb) XXXXXXXXXX; (cc) XXXXXXXXXX; (dd) XXXXXXXXXX; (ee) "taxable Canadian corporation" has the meaning assigned to that term in subsection 89(1) of the Act; and (ff) "US$" means United States dollars. ...
Ruling
2012 Ruling 2011-0421631R3 - Functional Currency Reporting
In the past, XXXXXXXXXX Holdco 2 has been used to directly or indirectly acquire XXXXXXXXXX % of the shares of selected active businesses operating outside of Canada and XXXXXXXXXX from arm’s length persons. ...
Ruling
2011 Ruling 2011-0396421R3 - Permanent Establishment
(d) "XXXXXXXXXX " is described in Paragraph 2. (e) "CRA" means the Canada Revenue Agency. ...
Ruling
2010 Ruling 2010-0383661R3 - Carrying on Business in Canada
Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2010 Ruling 2010-0360361R3 - Indian LP - 20(1)(c) Deduction
The interest rate on the Limited Partnership Promissory Note will be the prime rate as statistically monitored by the Bank of Canada plus XXXXXXXXXX %. ...
Ruling
2010 Ruling 2009-0352111R3 - 149.1(1) Related business - persons employed
Our understanding of the relevant definitions, the facts, proposed transaction and its purpose is as follows: DEFINITIONS XXXXXXXXXX; "Charity" means "XXXXXXXXXX ", incorporated pursuant to letters patent issued under the Canada Corporations Act dated XXXXXXXXXX An "employee" means a person employed and remunerated for that employment; and A "volunteer" in respect of the Facility means a person employed by the Charity in the carrying on of a business of the Charity who is not remunerated in any manner whatsoever for that employment. ...
Ruling
2009 Ruling 2009-0317831R3 - Loss Consolidation
Simple interest will accrue on each of the Subsidiary Loans and will be calculated daily at a rate equal to XXXXXXXXXX % per annum. ...
Ruling
2009 Ruling 2009-0348581R3 - Canada-U.S. Tax Convention ("Treaty")
As of XXXXXXXXXX, there were XXXXXXXXXX holders of record of US Parent's common stock, including US Holdings, which owned XXXXXXXXXX % of US Parent's common stock at that time. 3. ...
Ruling
2008 Ruling 2007-0257631R3 - Health Care Spending Account
It is anticipated that XXXXXXXXXX % of such sales employees will not receive a bonus in any given Bonus Year. 4. ...