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Technical Interpretation - External summary

18 October 2016 External T.I. 2015-0608051E5 F - Emigration of a trust -- summary under Subsection 220(4.5)

. [T]he trust must elect under subsection 220(4.5) on or before the 90th day after the trust ceases to be resident in Canada. ...
Technical Interpretation - External summary

7 March 2012 External T.I. 2011-0421301E5 F - Bien agricole admissible -- summary under Paragraph (a)

. [T]he forestry activities that take place on your farmland are farming. ...
Technical Interpretation - External summary

23 February 2012 External T.I. 2011-0421821E5 F - Test à l'alinéa 110.6(1)e) de la définition d'AAPE -- summary under Paragraph (e)

23 February 2012 External T.I. 2011-0421821E5 F- Test à l'alinéa 110.6(1)e) de la définition d'AAPE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (e) replaced shares need not be owned for a period of 24 months prior to their replacement but only for the portion of the 24 months before the time of disposition and ending at the replacement time Mr. ...
Technical Interpretation - External summary

23 January 2012 External T.I. 2011-0409671E5 F - Propriété superficiaire -- summary under Paragraph 1102(1)(c)

Indeed, under paragraph 1102(1)(c) depreciation is deductible only if the property was acquired for the purpose of gaining or producing income. ...
Technical Interpretation - External summary

23 February 2012 External T.I. 2011-0423461E5 F - Automobiles de collection -- summary under Paragraph 6(1)(e)

. Where a person is both a shareholder and an employee of a corporation and receives a benefit from that corporation, the Canada Revenue Agency generally considers that there is a presumption that the person benefited from that benefit as a shareholder where that person exercises significant influence over the conduct of the affairs of the corporation. ...
Technical Interpretation - External summary

22 February 2012 External T.I. 2011-0421671E5 F - Loss of retirement income benefit - death -- summary under Subparagraph 110(1)(f)(ii)

22 February 2012 External T.I. 2011-0421671E5 F- Loss of retirement income benefit- death-- summary under Subparagraph 110(1)(f)(ii) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(ii) deduction for WSIB compensation paid to estate of deceased injured worker An injured worker was entitled to receive monthly payments from the Ontario Workplace Safety and Insurance Board ("WSIB") until 65, with a lump sum paid to the worker at 65 as compensation for the loss of the monthly payments or to the worker’s survivors if he did not attain that age. ...
Technical Interpretation - External summary

6 December 2011 External T.I. 2010-0384701E5 F - Décès contribuable - Immobilisation admissible -- summary under Subsection 152(4.2)

After describing the application of s. 70(5.1) to the original bequest, and noting that its policy on price adjustment clauses did not apply in this situation, CRA stated: [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...
Technical Interpretation - External summary

14 March 2012 External T.I. 2011-0423291E5 F - Fiducie pour soi-même sans limite d'âge -- summary under Testamentary Trust

. [G]iven that the property would be the patrimony of an inter vivos trust, the transfer of the shares of a joint spousal or common-law partner trust will contaminate a future testamentary trust to be put in place on the death of Mr X or Ms X. ...
Technical Interpretation - External summary

30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale -- summary under Timing

. [P]repaid expenses or expenses that are paid before they are actually incurred are not deductible in computing a taxpayer's income. ...
Technical Interpretation - External summary

19 January 2012 External T.I. 2011-0414341E5 F - Déf revenu brut location Partie XIII -- summary under Subsection 216(4)

Where an amount on which an income tax is payable under Part XIII was paid to an agent for or on behalf of the non-resident person who is entitled to payment without the tax having been deducted or withheld, subsection 215(3) provides that it is then the responsibility of the agent to deduct or withhold the Part XIII tax payable in respect of the amount received on behalf of the non-resident. ...

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