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Technical Interpretation - Internal
24 December 2004 Internal T.I. 2004-0090011I7 - Commencement Day
The Queen, 2004 DTC 3300, at page 3309, determining whether a child is a "child of the marriage" is not an easy task: "However, the issue of whether one remains 'a child of the marriage' in accordance with the Divorce Act can be a tricky issue to resolve and will- in most cases, barring consent- require a decision by a competent tribunal. [...] ...
Technical Interpretation - Internal
21 March 2001 Internal T.I. 2000-0056297 - TENANT INDUCEMENT INVESTMENT ALLOWANCE
For example, see the definition "loan" adopted in McVey and McVey 2 and Simmonds & Sons. 3 In this case, there does not appear to have been any advance of funds from the taxpayer to the landlords or to third persons at the direction of the landlords. ...
Technical Interpretation - Internal
28 February 2002 Internal T.I. 2001-0112207 - Investment Tax Credit Percentage
Cameron Verification & Enforcement Division (613) 347-1361 Attention: XXXXXXXXXX Large File Case Manager 2001-011220 Specified Percentage and Investment Tax Credit ("ITC") We are writing further to your request for our views regarding certain "grandfathering" provisions found in the definition of "specified percentage" contained in subsection 127(9) of the Income Tax Act (the "Act"). ...
Technical Interpretation - Internal
1 May 2002 Internal T.I. 2001-0114347 - EXCLUDED PRODUCTION-25 YEAR PERIOD
., XXXXXXXXXX " (these XXXXXXXXXX productions are hereafter referred to as the "Productions")). ...
Technical Interpretation - Internal
23 October 2002 Internal T.I. 2002-0135797 - FOREIGN EXCHANGE LOSSES
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
31 October 2002 Internal T.I. 2002-0142497 - FOREIGN EXCHANGE LOSSES
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
27 November 2002 Internal T.I. 2002-0140507 - FOREIGN EXCHANGE LOSS
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
27 November 2002 Internal T.I. 2002-0140517 - FOREIGN EXCHANGE LOSS
In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal
25 February 2003 Internal T.I. 2003-0001677 - DEMUTUALIZATION CONVERSION BENEFIT
February 25, 2003 XXXXXXXXXX TSO HEADQUARTERS Business Enquiries Financial Institutions Section Verification & Enforcement Division Income Tax Rulings Directorate Attention: XXXXXXXXXX Alison Campbell (613) 957-3496 2003-000167 Demutualization Payments to Employees We are replying to your request for assistance in determining the appropriate application of section 139.1 of the Income Tax Act, in respect of a particular taxpayer. ...
Technical Interpretation - Internal
25 January 2000 Internal T.I. 1999-0006847 - REQUEST RECEIVED BY NPO
We trust that our comments will be of assistance to you. for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...