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Ruling

2000 Ruling 2000-0003223 - DIRECTOR PHANTOM STOCK PLAN

Yours truly, for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...
Technical Interpretation - Internal

20 April 2000 Internal T.I. 2000-0000217 - Offshore Trusts

., 3 & 6. See comments under Position. 4. Because of the 60-month exemption, the trust has no change in residence at the time that the contributor becomes resident in Canada; however the trust does become resident in Canada on January 1 of the year in which the conditions in 94(1)(a) and (b) are met such that a deemed disposition under 128.1(1) occurs before the trust becomes resident in Canada. 5. ...
Technical Interpretation - Internal

13 April 2000 Internal T.I. 1999-0011917 - CEE; Resource Allowance; Recovery Expense

"concept of source of production in resource allowance provisions is broader than in legislation where "development" must be distinguished from "production" April 13, 2000 Calgary Tax Services Office Resource Industries Section Denise Dalphy Attention: Bharat Patel (613) 957-9231 Oil & Gas Specialist 991848 1999-001191 Costs of Tangible Capital Property This is in reply to you facsimile transmission of July 7, 1999 concerning submissions dated June 2 and 18, 1999 that you received from XXXXXXXXXX. ...
Ruling

1999 Ruling 9905543 - PAID-UP CAPITAL/ORDINARY COURSE OF BUSINESS

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling

1999 Ruling 9906933 - MUTUAL FUNDS

XXXXXXXXXX 3-971404 / 3-990693 Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs/Madams: Re: Advance Income Tax Rulings XXXXXXXXXX We are writing in reply to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling under the Income Tax Act (Canada) (the "Act") on behalf of XXXXXXXXXX in respect to the facts and proposed transactions described below. ...
Ruling

2000 Ruling 2000-0011903 - PHANTOM STOCK PLAN DISPOSTITION OF SUB.

These rulings are given subject to the limitations and qualifications set forth in Canada Customs & Revenue Agency (the "Agency") Information Circular 70-6R3 dated December 30, 1996, and are binding upon the Agency provided the Plan is implemented on or before XXXXXXXXXX. ...
Ruling

2000 Ruling 2000-0040663 - Butterfly reorganization

The more significant marketable securities are: (a) an approximately XXXXXXXXXX% interest in the common shares of the XXXXXXXXXX; (b) an approximately XXXXXXXXXX% interest in the common shares of XXXXXXXXXX; (c) approximately XXXXXXXXXX% of the XXXXXXXXXX shares and XXXXXXXXXX% of the XXXXXXXXXX shares of XXXXXXXXXX; and (d) approximately XXXXXXXXXX% of the XXXXXXXXXX common shares and XXXXXXXXXX% of the XXXXXXXXXX " shares of XXXXXXXXXX. ...
Ruling

2000 Ruling 2000-0034813 - Partnership Reorganization

He will be a shareholder and director of Newco and will establish a corporation ("XXXXXXXXXX ") that will become a Contracting Company. 33. ...
Ruling

2000 Ruling 2000-0049383 - related persons divisive reorganization

ADMINISRATIVE MATTERS: The taxpayers' names and Social Insurance Numbers / Business Numbers are as follows: XXXXXXXXXX /Mother XXXXXXXXXX XXXXXXXXXX /Child 1 XXXXXXXXXX XXXXXXXXXX GROUP Related and Associated Companies XXXXXXXXXX /Aco XXXXXXXXXX XXXXXXXXXX /Bco XXXXXXXXXX XXXXXXXXXX. ...
Ruling

1998 Ruling 982599A - JOINT VENTURE - TAX SHELTER

., B Co. and other persons related to A Co. for purposes of the Act.have generally participated in approximately XXXXXXXXXX % of the funding for XXXXXXXXXX joint venture program. 7. ...

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