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Technical Interpretation - Internal summary
23 June 2014 Internal T.I. 2013-0501521I7 - Collection Limitation Period -- summary under Subsection 222(3)
. … After the end of the limitation period, the CRA may not take collection actions; however, the debt remains payable by the taxpayer and the CRA will accept payments on account of the debt. ...
Conference summary
17 May 2012 IFA Conference Roundtable, 2012-0444091C6 - Definition of taxable Canadian property -- summary under Paragraph (d)
17 May 2012 IFA Conference Roundtable, 2012-0444091C6- Definition of taxable Canadian property-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (d) proportionate consolidation/debt look-through In determining (when a non-resident disposes of shares of Parent) what portion of the shares of the Subsidiary of Parent represent real or immovable property of Parent, CRA will apply to the fair market of the shares of Subsidiary the proportion which the real or immovable property of Subsidiary represents of its total gross assets – and the same approach is applied respecting a subsidiary partnership. ...
Technical Interpretation - External summary
4 April 2013 External T.I. 2012-0444581E5 F - Frais de garde - hébergement en famille d'accueil -- summary under Child Care Expense
However … lodging expenses with a host family are not amounts paid to a sports school providing lodging services, and, consequently, they are not child care expenses for the purposes of subsection 63(3). ...
Technical Interpretation - External summary
26 February 2015 External T.I. 2015-0569601E5 F - Contribution to a TFSA -- summary under Paragraph 146.2(5)(c)
. … If the facts surrounding the transaction demonstrate that a person has contributed to his spouse's TFSA, paragraph 146.2(2 (c) would not be complied with and, pursuant to paragraph 146.2(5)(b), the TFSA would cease to be a qualifying arrangement. ...
Technical Interpretation - External summary
4 July 2014 External T.I. 2013-0515541E5 - Life annuity payment out of an RCA -- summary under Eligible Pension Income
However, to qualify as eligible pension income, the RCA benefits must … be payable in substantially the same form as the RPP benefits (i.e. payable for life in equal periodic amounts subject to inflation or other adjustments permitted under the RPP). ...
Technical Interpretation - External summary
10 November 2014 External T.I. 2014-0536851E5 F - Terre à bois et Plan d'aménagement forestier -- summary under Paragraph 73(3)(c)
. … However, where there is a FMP, the taxpayer must simply demonstrate that one of the persons listed in paragraph 73(3)(c) was involved in the farming business to the extent required by the FMP. ...
Technical Interpretation - External summary
23 January 2014 External T.I. 2013-0515721E5 F - Deferred Salary Leave Plan -- summary under Subparagraph 6801(a)(v)
. … Consequently, if an employee works full-time before the start of a one-year leave, it would not be sufficient in the context of a DSLP to return to employment for a period of two years on a part-time basis, and the condition in subparagraph 6801(a)(v) would not be satisfied. ...
Conference summary
16 June 2014 STEP Roundtable, 2014-0523011C6 - STEP Roundtable 2014-7(1)(e) -- summary under Subsection 164(6.1)
. … ...
Conference summary
5 October 2012 Roundtable, 2012-0453141C6 F - RCA, prohibited investment -- summary under Advantage
However … given that the terms and conditions of these types of contracts may vary significantly, we are unable to comment on the application of the concept of advantage to co-ownership agreements or split-premium life insurance arrangements. ...
Technical Interpretation - External summary
12 February 2015 External T.I. 2014-0550771E5 F - Allocation à des bénévoles - chantier particulier -- summary under Subsection 6(6)
. … Furthermore, the CRA generally considers that the rates…established by the Council…to be fair and reasonable. ...