Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

7 May 1991 Income Tax Severed Letter- Stock appreciation rights — cash in lieu of shares Unedited CRA Tags 7, 110(1)(d) Dear Sirs: Re: Stock Appreciation Rights ("SAR") Cash in Lieu of Shares This is in reply to your letter of March 27, 1991 concerning the above-mentioned subject. ...

7 November 1990 Income Tax Severed Letter- Amalgamations — depreciable property Unedited CRA Tags 251(3.1), Reg. 1102(14)(d) QUESTION I 56 Amalgamations- Depreciable Property Does the Department consider that, on an amalgamation, subsection 251(3.1) would apply for purposes of paragraph 1102(14)(d) of the Income Tax Regulations so that the corporation resulting from the amalgamation would be considered to have acquired property from a person with which it was not dealing at arm's length at the time the property was acquired? ...

7 October 1990 Income Tax Severed Letter- Employee benefits — retirement counselling services Unedited CRA Tags none Dear Sirs: Re: Employment Benefits- Retirement Counselling Services This is further to your letter of July 16, 1990 concerning the proposed amendment to paragraph 6(1)(a) of the Act to exclude benefits received by an employee derived from counselling services in respect of his/her re-employment or retirement. ...

7 February 1991 Income Tax Severed Letter- Advanced tax rulings — repayment of fees Unedited CRA Tags Interpretation Act 31(2) Dear: XXX Mr. ...

7 November 1990 Income Tax Severed Letter- Depreciable property — allocation of proceeds on death Unedited CRA Tags 70(5)(b) QUESTION I-99 DEPRECIABLE PROPERTY- ALLOCATION OF PROCEEDS ON DEATH Assume a taxpayer dies owning several assets of the same class of depreciable property. ...

7 December 1991 Income Tax Severed Letter- Deferred salary leave plans — leave period Unedited CRA Tags Reg. 6801(a)(i) Dear Sir: Re: Deferred Salary Leave Plans- Leave Period This is in response to our telephone conversation (Baldwin/XXX) on December 11, 1991 concerning paragraph 6801(a)(i) of the Income Tax Regulations. ...

7 November 1991 Income Tax Severed Letter- Shareholders' agreement — term preferred shares Unedited CRA Tags 248(1) Question 25- Shareholders' Agreement- Term Preferred Shares Shareholders' agreements may include provisions which require that a shareholder wishing to sell his shares may only do so if the same offer is made by the prospective purchaser to the other shareholders. ...

12 March 1981 Income Tax Severed Letter RRRR38- Foreign accrual property income taxation — deceased individual Unedited CRA Tags 94(1)(b)(i)(B), 94(1)(b)(i)(C) XXX This is in reply to your letter of February 13 concerning clauses 94(1)(b)(i)(B) and (C) of the Income Tax Act. ...

18 July 1980 Income Tax Severed Letter RRRR13- Transfer by non-resident of registered pension plan amounts — Forest et al decision Unedited CRA Tags 204.1, 212(1)(h) This is in response to your memo of July 16 concerning the implications of the recent Federal Court case of Forest et al (1980 DTC 6149). ...

29 April 1980 Income Tax Severed Letter RRRR10- Non-resident individual employed in Canada — rollover of retiring allowance into registered retirement savings plan Unedited CRA Tags 60(j), 2(3), 248(1), 217 A non-resident individual has been employed as president of a Canadian company for several years and recently received a retiring allowance. ...