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Ruling

2010 Ruling 2009-0352111R3 - 149.1(1) Related business - persons employed

Our understanding of the relevant definitions, the facts, proposed transaction and its purpose is as follows: DEFINITIONS XXXXXXXXXX; "Charity" means "XXXXXXXXXX ", incorporated pursuant to letters patent issued under the Canada Corporations Act dated XXXXXXXXXX An "employee" means a person employed and remunerated for that employment; and A "volunteer" in respect of the Facility means a person employed by the Charity in the carrying on of a business of the Charity who is not remunerated in any manner whatsoever for that employment. ...
Ruling

2009 Ruling 2009-0317831R3 - Loss Consolidation

Simple interest will accrue on each of the Subsidiary Loans and will be calculated daily at a rate equal to XXXXXXXXXX % per annum. ...
Ruling

2009 Ruling 2009-0348581R3 - Canada-U.S. Tax Convention ("Treaty")

As of XXXXXXXXXX, there were XXXXXXXXXX holders of record of US Parent's common stock, including US Holdings, which owned XXXXXXXXXX % of US Parent's common stock at that time. 3. ...
Ruling

2008 Ruling 2007-0257631R3 - Health Care Spending Account

It is anticipated that XXXXXXXXXX % of such sales employees will not receive a bonus in any given Bonus Year. 4. ...
Ruling

2008 Ruling 2008-0269991R3 - Partner creating contracting company

(b) Each calendar month, a Partner is entitled to a "Monthly Income Allocation" based on XXXXXXXXXX % of all funds received in that month to the account of fees billed and collected by that Partner. ...
Ruling

2007 Ruling 2006-0216551R3 - Interest Expense - Substituted Property

The consideration provided by Finance Co was common shares of Finance Co with a fair market value equal to the fair market value of XXXXXXXXXX % of the B Co Shares. ...
Ruling

2007 Ruling 2006-0201321R3 - Borrowed money, shares of subsidiary

Interest payable on XXXXXXXXXX Certificates of Deposit is XXXXXXXXXX% per annum each and one Certificate of Deposit carries an interest rate of XXXXXXXXXX %. ...
Ruling

2007 Ruling 2007-0260861R3 - Entity Classification

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2007 Ruling 2007-0242361R3 - Donation of flow-through shares

This holding will represent less than XXXXXXXXXX % of the outstanding shares of the Resource Company. ...
Ruling

2007 Ruling 2007-0252491R3 - Assumption of debt for assets

The notes bear interest at the rate of XXXXXXXXXX % per annum and mature on XXXXXXXXXX. ...

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