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Conference summary

28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3 -- summary under Subsection 212.3(2)

. However…the amount of the deemed dividend would be equal to nil. …The deemed disposition and reacquisition of shares pursuant to paragraph 111(4)(e) would neither constitute a transfer of any property by the CRIC for purposes of paragraph 212.3(2)(a) nor would it constitute any of the other amounts referred to in subsection 212.3(2)(a). ...
Technical Interpretation - External summary

11 September 2014 External T.I. 2013-0495091E5 - Reimbursement of employee's foreign tax -- summary under Paragraph 6(1)(a)

. [T]he employer would be required to withhold a portion of the reimbursement payments in accordance with [Reg.] 102…. ...
Technical Interpretation - External summary

17 October 2014 External T.I. 2014-0532121E5 F - Frais professionnels - Divulgation volontaire -- summary under Paragraph 60(o)

See summary under s. 18(1)(a) legal fees. ...
Technical Interpretation - External summary

22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation -- summary under Know-How and Training

. [W]here training is undertaken to maintain, update or upgrade a skill used in the course of a business, the exercise of a profession or a commercially viable activity of a participant, the costs of registration for a training, which may include travel and meal expenses, is deductible as a current expense. ...
Conference summary

5 October 2012 Roundtable, 2012-0453581C6 F - Somme payable - revenus de placements -- summary under Subsection 104(24)

CRA stated: [T]he acknowledgement of debt does not appear to satisfy the conditions set out above. ...
Technical Interpretation - External summary

6 August 2013 External T.I. 2012-0469481E5 F - Benefit under trust -- summary under Subsection 105(1)

Accordingly, that difference represented a taxable benefit to the purchaser, but such amount was required to be added to the purchaser's adjusted cost base under s. 52(1) with a resulting reduction in the capital gain on the subsequent sale. ...
Technical Interpretation - External summary

6 August 2013 External T.I. 2012-0469481E5 F - Benefit under trust -- summary under Subsection 52(1)

Accordingly, that difference represented a taxable benefit to the purchaser, but such amount was required to be added to the purchaser's adjusted cost base under s. 52(1) with a resulting reduction in the capital gain on the subsequent sale. ...
Technical Interpretation - External summary

13 March 2014 External T.I. 2013-0510791E5 - Non-cash long-service award and cash donation -- summary under Subsection 56(2)

. Therefore, in light of the fact that the first $500 of a non-cash long-service award would have been non-taxable if it were received by the employee, it is our view that only the amount of the donation that exceeds $500 would be required to be included in the employee's income. ...

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