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Technical Interpretation - Internal

13 October 2011 Internal T.I. 2011-0395991I7 - Adjusted Ontario SR&ED Incentive Balance

Subsection 49(7) of the TA provides the formula to calculate the adjusted Ontario SR&ED incentive balance as: (M- N- P) / C The variable "M" is the "adjusted gross federal investment tax credit" at the end of the 2008 taxation year. ...
Technical Interpretation - Internal

25 August 2011 Internal T.I. 2011-0396021I7 - Reallocation of Interest

.), at 20. Those provisions do not permit a refund of an overpayment of tax, rather they give the Minister the discretion to re-appropriate an amount from one debt to another. ...
Technical Interpretation - Internal

16 December 2010 Internal T.I. 2010-0354101I7 - Salary Deferral Arrangement

According to the terms of the arrangement, the employee received 80 % of his usual salary for four years, deferring 20% each year for four years to be received in the fifth year (the "Sabbatical Year"). ...
Technical Interpretation - Internal

9 August 2011 Internal T.I. 2011-0410301I7 - Offset of Post-Bankruptcy Refunds

9 August 2011 Internal T.I. 2011-0410301I7- Offset of Post-Bankruptcy Refunds Unedited CRA Tags s. 152(1), 159(3), 160(1), 164(2), 224(4), 227(4), & (4.1) ITA; 227.1(1); s. 270(4), 317(7), 323(1), 325(1) ETA; s. 67(1)(c), 97(3) BIA Principal Issues: Whether a refund for the calendar year of a bankruptcy can be offset? ...
Technical Interpretation - Internal

27 July 2010 Internal T.I. 2010-0374771I7 - Notice of Assessment Bearing Mistaken Information

27 July 2010 Internal T.I. 2010-0374771I7- Notice of Assessment Bearing Mistaken Information Unedited CRA Tags s. 128.1(1); s. 152((1), (3), (3.1), & (4) Principal Issues: Whether mistaken information on a notice of assessment is fatal to its legal effectiveness. ...
Technical Interpretation - Internal

11 March 2010 Internal T.I. 2009-0352551I7 - Foreign exchange losses

Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal

25 October 2010 Internal T.I. 2010-0378361I7 - Sabbatical leave - Indian Employee

The information that you have provided to us indicates that the Employee is entitled to take a XXXXXXXXXX month sabbatical leave at XXXXXXXXXX % of his full-time salary after XXXXXXXXXX years of creditable service at the University. ...
Technical Interpretation - Internal

8 June 2008 Internal T.I. 2008-0294291I7 - Deadline for filing a waiver of tax credit - OITC

8 June 2008 Internal T.I. 2008-0294291I7- Deadline for filing a waiver of tax credit- OITC Unedited CRA Tags TA 96(14) ITA 150(1)(a), 37(11) & 127(9)(m) Principal Issues: Can a corporation file a waiver of tax credit under subsection 96(14) of the Taxation Act, 2007 (TA) to waive all or part of its Ontario Innovation Tax Credit (OITC) after the deadline for the filing of its income tax return for the year? ...
Technical Interpretation - Internal

5 November 2009 Internal T.I. 2009-0315901I7 - stop-loss rules - financial institutions

For example, the wording could have been "... this subsection applies to a disposition of a share by a taxpayer in the taxation year" as opposed to "at any time". ...
Technical Interpretation - Internal

28 April 2017 Internal T.I. 2017-0699741I7 - Phoenix - financial advisor funding

As noted in paragraph 2.9 of this folio: 2.9 Generally, “the value of board, lodging, and other benefits of any kind whatever received or enjoyed in respect of, in the course of, or by virtue of an office or employment” is included in an employee’s income under paragraph 6(1)(a). ...

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