Search - 哈尔滨到北京 公里数
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Technical Interpretation - Internal summary
13 January 2012 Internal T.I. 2011-0414111I7 F - Deemed Interest Incomes - Exception 17(8) -- summary under Subparagraph 17(8)(a)(ii)
In this regard, CRA quoted a judicial statement that "the courts have concluded that the concept of loan or advance is related to the existence of a payment of money between two parties and to the presence of that relationship of lender / borrower," and then stated: [T]he contractual relationship between CFA 1 and CFA 2 with respect to the Debt establishes a creditor/debtor relationship and not a lender/borrower relationship. ...
Technical Interpretation - External summary
28 June 2010 External T.I. 2009-0329511E5 - United States - Dividend Withholding Rate -- summary under Article 29A
. … Under subparagraph 2(a) [of Article X], the S-Corp would be considered to own the shares of Canco owned by the US LLC.... ...
Conference summary
8 October 2010 APFF Roundtable, 2010-0373301C6 F - Classes of shares with identical characteristics -- summary under Subsection 47(1)
. … The question would therefore be whether, depending on the facts and circumstances of a particular situation, shares of different classes have exactly the same rights and restrictions. ...
Conference summary
1 May 2009 IFA Roundtable Q. 12, 2009-0320231C6 F - Convertible Debt Obligations -- summary under Participating debt interest
CRA stated: Where there is a conversion of a traditional convertible debenture by its original holder for common shares of the issuer, … in general there would be no Excess under subsection 214(7)…. ...
Conference summary
1 May 2009 IFA Roundtable Q. 12, 2009-0320231C6 F - Convertible Debt Obligations -- summary under Subsection 214(7)
CRA stated: Where there is a conversion of a traditional convertible debenture by its original holder for common shares of the issuer, … in general there would be no Excess under subsection 214(7)…. ...
Technical Interpretation - Internal summary
Memorandum 17-6 "Definition of ‘Listed Financial Institution'" July 2014 -- summary under Paragraph 149(1)(a)
. … CRA considers that "principal" refers to the person's chief or main business activity. ...
Ruling summary
2004 Ruling 2003-0053981R3 - XXXXXXXXXX -- summary under Paragraph 107.4(3)(m)
If the Fund had not acquired any additional units … the contribution to the Trust would not increase the Fund's ACB of its capital interest in the Trust, notwithstanding that it would increase the FMV of its capital interest in the Trust. ...
Technical Interpretation - External summary
12 August 2010 External T.I. 2010-0370551E5 F - Tuck Under Transaction - Tremblay Decision -- summary under Subsection 84(2)
After noting in its summary that “ Tremblay... contains a strong dissent based on... ...
Technical Interpretation - External summary
26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie -- summary under Testamentary Trust
Consequently, whether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) – or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...
Technical Interpretation - External summary
26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie -- summary under Subsection 248(25)
In finding that the purported testamentary trust would not qualify because its contingent interest in the inter vivos trust was not property contributed to it by the deceased, CRA stated: [W]hether such capital or income interest in the inter vivos trust is a future or conditional interest, a trust established by will would lose its status as a testamentary trust within the terms of subsection 108(1) – or not acquire that status in the first place- if it received an interest in an inter vivos trust. ...