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Technical Interpretation - External summary

24 January 2005 External T.I. 2004-0099471E5 F - Convention de retraite pour un actionnaire-employé -- summary under Paragraph 56(1)(x)

After paraphrasing the s. 20(1)(r) wording, indicating that, to be deductible, “the contributions must relate to services rendered to that corporation as an employee” and discussing the s. 67 limitation, CRA stated: [T]hat subsection does not restrict the contributions necessary to fund an RCA. ...
Technical Interpretation - External summary

3 February 2005 External T.I. 2005-0112141E5 F - Safe income -- summary under Paragraph 55(2.1)(c)

A, who held ½ of the common shares of Opco having a PUC and ACB of $100, a safe income on hand of $699,900 and a fair market value of $1,000,000, transferred his common shares to a new corporation (“Holdco”) in consideration for common shares of Holdco, with the s. 85(1) agreed amount being $300,000, thereby realizing a $299,900 capital gain for which he claimed the capital gains deduction. ...
Technical Interpretation - External summary

2 February 2005 External T.I. 2004-0104671E5 F - Convention de retraite - Fonds mis de côté -- summary under Retirement Compensation Arrangement

. Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...
Technical Interpretation - External summary

23 February 2005 External T.I. 2004-0093921E5 F - Déménagement d'un employé-Paiement de frais -- summary under Paragraph 6(1)(a)

. While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. ...
Technical Interpretation - External summary

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.5(2)

. [T]he custodian of an RCA who holds a letter of credit would not be able to make the election under subsection 207.5(2). ...
Technical Interpretation - External summary

17 April 2001 External T.I. 2000-0056455 F - AVANTAGE IMPOSABLE-EMPLOYE -- summary under Paragraph 6(1)(a)

For example [there would be such] benefit if one of the conditions of remaining a capital beneficiary was to continue to be employed by Opco, so as to render services to Opco.... ...
Technical Interpretation - External summary

28 June 2001 External T.I. 2001-0069865 F - CRÉDIT-BAIL -- summary under Subsection 248(3)

. [P]aragraph 248(3)(f) essentially restates what subsection 248(3) provided at the time, except that the wording is now different and cannot be interpreted as in the Construction Bérou Inc. case. ...
Technical Interpretation - External summary

22 June 2001 External T.I. 2001-0075275 F - Dommages-intérêts -- summary under Paragraph 12(1)(c)

. Consequently, any compensation received by a taxpayer pursuant to Article 1617 of the CCQ constitutes interest income to the taxpayer (see No. 484 v. ...
Technical Interpretation - External summary

21 November 2001 External T.I. 2000-0062895 F - BOURSE D'ETUDES OU REVENU D'EMPLOI -- summary under Subsection 5(1)

21 November 2001 External T.I. 2000-0062895 F- BOURSE D'ETUDES OU REVENU D'EMPLOI-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee but could be non-taxable as primarily for employer’s benefit A professional services firm recruits university students and offers them a sum of money to cover the cost of their studies. ...
Technical Interpretation - External summary

21 January 2002 External T.I. 2001-0078735 F - Droit de recevoir une somme -- summary under Proceeds of Disposition

21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved The shareholders of a Canadian-controlled private corporation (Xco) agreed to sell their Xco shares to a public corporation (Yco) in consideration for an upfront cash payment, and for shares of Yco received on an s. 85(1) rollover basis but with a clause (the “Clause”) in the sale agreement providing that in one year’s time they would receive a further cash payment for each of their Yco shares equal to the deficiency in its trading price in one year’s time as compared to the portion of the sale price allocated to such shares. ...

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