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Ruling

2001 Ruling 2001-0108473 - XXXXXXXXXX INTEREST DEDUCTIBILITY

The XXXXXXXXXX Securities are expected to represent approximately XXXXXXXXXX % of the total capital of the Trust represented by units, will be voting and will be subscribed for cash. ...
Ruling

2002 Ruling 2001-0103053 - CFA Branch, exempt earnings

In accordance with the XXXXXXXXXX, FA2 will pay XXXXXXXXXX tax on its profits and gains at rates varying between XXXXXXXXXX % depending on its amount of profits. ...
Ruling

2002 Ruling 2001-009107A - Mutual Fund Trust-Capital Gains

Position: 1) Yes 2) No 3) No REASONS: The position taken with respect to the allocation of capital gains to redeeming unitholders and for determining the proceeds of disposition on such redemptions is consistent with the position taken in previous rulings (Doc # 981758 and 2000-004136). ...
Ruling

2002 Ruling 2002-0126853 - PATRONAGE DIVIDENDS

Subject to adjustments as contemplated in the Agreements, DCO will pay a membership fee in the amount of $XXXXXXXXXX plus XXXXXXXXXX % of audit and legal fees, and BCO will pay a membership fee in the amount of $XXXXXXXXXX plus XXXXXXXXXX% of audit and legal fees. 20. ...
Ruling

2002 Ruling 2002-0145983 - EMPLOYEE STOCK OPTION PLAN

Pursuant to the power granted it under paragraph XXXXXXXXXX of the Plan, as described in 15 above, the Board proposes to amend the first sentence of paragraph XXXXXXXXXX of the Plan as described in 12 above, by deleting the words ", other than a holder that is subject to tax under the Income Tax Act (Canada) in respect of such SAR," as well as the word "may" where it currently appears before "require", so that the sentence would read as follows: "The Board may, in its discretion at the time of grant or at any time thereafter, upon the exercise of an SAR, require a holder electing to exercise an SAR to receive cash in lieu of Common Shares. ...
Ruling

2002 Ruling 2002-0138413 - INTEREST DEDUCTIBILITY FINANCING FEES

Position: 1. a) & b)- interest is deductible 1 c)- Opinion provided based on proposed legislation pursuant to 20.2. 2. ...
Ruling

2002 Ruling 2002-0161413 - Derivatives - Foreign property rules

Reasons: Similar to ruling # E 2001-0079143. XXXXXXXXXX 2002-016141 XXXXXXXXXX, 2002 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the income tax consequences arising from the proposed transactions described below. ...
Ruling

2002 Ruling 2002-0168603 - XXXXXXXXXX

The Pubco Notes will have a XXXXXXXXXX-year term and annual interest rate of approximately XXXXXXXXXX %, payable semi-annually. ...
Ruling

2002 Ruling 2002-0177133 - LOSS UTILIZATION

B Co's audited consolidated financial statements for the year ended XXXXXXXXXX indicate that B Co had, on a consolidated basis: Long-term debt of approximately $ XXXXXXXXXX; A weighted average rate of borrowing on the long-term debt of XXXXXXXXXX%; Shareholders' equity of approximately $XXXXXXXXXX; and Short-term notes payable of approximately $XXXXXXXXXX. ...
Ruling

2003 Ruling 2003-002183A - Underground Exploration Program - CEE?

"investment tax credit" " has the meaning assigned to that expression by subsection 127(9) of the Act. ...

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