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Conference summary
5 October 2012 Roundtable, 2012-0453181C6 F - Person affiliated with RESP and RDSP -- summary under Paragraph 251.1(1)(g)
. … Finally, any person who would be affiliated with a majority-interest beneficiary in a particular RDSP Trust in the absence of paragraph 251.1(1)(g), should generally be affiliated with such trust. ...
Ruling summary
2013 Ruling 2013-0502921R3 - Split-Up Butterfly - Farm -- summary under Subsection 186(1)
" See more detailed summary under s. 55(1) – distribution. ...
Technical Interpretation - External summary
4 June 2014 External T.I. 2014-0517151E5 - S. 17.1 and debt denominated in foreign currency -- summary under Subsection 17.1(1)
. … Element B of the formula is the amount actually included in the CRIC's income on account of the interest with respect to the PLOI. ...
Technical Interpretation - External summary
4 June 2014 External T.I. 2014-0517151E5 - S. 17.1 and debt denominated in foreign currency -- summary under Subsection 261(2)
. … Element B of the formula is the amount actually included in the CRIC's income on account of the interest with respect to the PLOI. ...
Technical Interpretation - External summary
25 September 2013 External T.I. 2013-0497011E5 F - OETC - Qualifying period -- summary under Subsection 122.3(1)
. … Periods of absence from the workplaces abroad, in order to be included in the qualifying period, will generally have to be related to the contract with respect to the activities that are qualifying or consequential to the latter and the contract must be of a duration of more than six consecutive months in order for the employer to be considered to have carried on a business outside Canada for the purpose of the application of the OETC. ...
Technical Interpretation - External summary
10 December 2012 External T.I. 2011-0429721E5 F - OETC - Employee stock options benefits -- summary under Paragraph 122.3(1)(d)
However, the CRA's long-standing position is that … the amount of the employment benefit calculated in paragraph 7(1)(a) generally relates to the duties performed during the year in which stock options are granted unless the facts, circumstances and relevant documents clearly demonstrate that the options were granted to compensate for future services. ...
Technical Interpretation - External summary
10 December 2012 External T.I. 2011-0429721E5 F - OETC - Employee stock options benefits -- summary under Subparagraph 115(1)(a)(i)
However, the CRA's long-standing position is that … the amount of the employment benefit calculated in paragraph 7(1)(a) generally relates to the duties performed during the year in which stock options are granted unless the facts, circumstances and relevant documents clearly demonstrate that the options were granted to compensate for future services. ...
Technical Interpretation - External summary
29 May 2014 External T.I. 2014-0520851E5 F - Deferred Salary Leave Plan -- summary under Subparagraph 6801(a)(i)
However … CRA's position is that the terms and conditions of a DSLP agreement generally cannot provide for the voluntary withdrawal from a plan by a participating employee. ...
Ruling summary
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT -- summary under Qualifying Exchange
2013 Ruling 2013-0488351R3- Conversion of a MFC to a MFT-- summary under Qualifying Exchange Summary Under Tax Topics- Income Tax Act- Section 132.2- Subsection 132.2(1)- Qualifying Exchange conversion of MFC to MFT and subtrust elimination The same (mutual fund corporation) taxpayer as for 2013 Ruling 2011-0395091R3 ("MFC to MFT Conversion") (immediately below) obtained essentially the same rulings for transactions which now reflected its acquisition of "Target" trust before the implementation of the merger of the taxpayer under s. 132.2 into REIT #1 (the internally-created replacement mutual fund trust) and the elimination of various subtrusts using s. 107.4 (or s. 248(1) – non-disposition) transfers and the s. 132.2 merger rules. ...
Ruling summary
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT -- summary under Subsection 21(1)
See detailed summary under s. 132.2(1) – qualifying exchange. ...