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
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Ruling
1999 Ruling 9922913 - POST MORTEM PLANNING - 164(6)
These shares represented XXXXXXXXXX % of the issued and outstanding share capital of XXXXXXXXXX, respectively. 7.1 XXXXXXXXXX. 7.2 XXXXXXXXXX. 7.3 XXXXXXXXXX. 7.4 XXXXXXXXXX. 8. ...
Ruling
1999 Ruling 9908523 - INTERNAL REORGANIZATION -SPIN-OFF
. $ XXXXXXXXXX): XXXXXXXXXX. PROPOSED TRANSACTIONS The parties propose to enter into the following transactions on a date (the "Transaction Date") as early as practical after receiving the rulings given in this letter, provincial tax rulings, United States tax rulings and XXXXXXXXXX: 17. ...
Ruling
1999 Ruling 9832453 - DISPOSITION OF DEBT: INTEREST DEDUCTIBILITY
To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
2000 Ruling 2000-0028423 - partnership dissolution under 98(3)
Avoid double tax 4. transactions arranged for other than tax purposes; no misuse / abuse XXXXXXXXXX 2000- 002842 Attention: XXXXXXXXXX XXXXXXXXXX, 2000 Dear Sirs: Re: XXXXXXXXXX Advance Income Tax Rulings We are writing in response to your letter of XXXXXXXXXX wherein you requested advance income tax rulings on behalf of the above taxpayer. ...
Ruling
1999 Ruling 9902593 - STOCK OPTIONS - CASH-OUT RIGHT
Where an employee of Employer exercises the Cash Out Right, and Employer pays the Cash Amount to the employee: (a) the Cash Amount received by the employee in respect of the economic value of the Subscription Right exchanged for the cancellation of that Subscription Right under the Subscription Rights Plan will be included in computing the income of the employee in the taxation year in which the Cash Amount is received by the employee in accordance with paragraph 7(1)(b) of the Act; and (b) assuming the conditions specified in subparagraphs 110(1)(d) are met with respect to the Foreign Parentco Shares and the Subscription Rights Plan, the employee may deduct 25 % of the Cash Amount in computing his or her taxable income for the taxation year in which the Cash Amount is received. ...
Ruling
1999 Ruling 9817583 - MUTUAL FUND TRUST - CAPITAL GAINS ALLOCATION
Also, see Doc # 32954. As there are good business reasons for undertaking the proposed transactions, the proposals are not avoidance transactions and GAAR should not be applied. ...
Ruling
1999 Ruling 9920613 - INTER-CORPORATE DIVIDENDS
To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
1998 Ruling 98021433 - REPAYMENT OF INDEBT. 18(9.1) ON REFINANC.
The Existing Bonds bear interest at a rate of XXXXXXXXXX % per annum, payable semi-annually in arrears. ...
Ruling
1998 Ruling 9828683 - STOCK DIVIDEND
To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...
Ruling
1999 Ruling 9904563 - 164(6) - POST MORTEM PLAN
Each Class D share will be entitled to vote, will be redeemable and retractable for $XXXXXXXXXX per share, will have the right to receive an annual XXXXXXXXXX % cumulative dividend and will have priority over common shares on a wind-up or liquidation. 19.3XXXXXXXXXX will issue one Class D share to Holdco for $XXXXxXXXXX cash consideration. 20. ...