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Technical Interpretation - External summary
29 August 1995 External T.I. 9506785 - PROPERTY...IN WHICH BUSINESS OF CO CARRIED ON -- summary under Article 13
Carried on"): Respecting the exclusion in Article XIII, paragraph 4 of the Canada-Netherlands Convention for property (other than rental property) in which the business of the company is carried on, RC stated that in its view "Oil & Gas reserves and royalty interests will be excluded from the definition of immovable property... if the owner is actively engaged in the exploitation of natural resources and if such assets are actively exploited or kept for future exploitation by such owner.... ...
Technical Interpretation - External summary
10 January 1996 External T.I. 9518515 - Transfers of property to revocable living trusts -- summary under Subsection 104(1)
. … [B]y virtue of point (4) above, the settlor would not retain all incidents of beneficial ownership. ...
Conference summary
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 1, 2018-0761521C6 F - Life insurance policy as share redempt. proceeds -- summary under Subsection 148(7)
In effectively answering “$100,000,” CRA stated: [T]he word "consideration" must, for the purposes of subsection 148(7), receive the broad meaning generally accorded to it in the jurisprudence … [so that where] on a share redemption, the redemption price paid by a corporation is an interest in a life insurance policy that the corporation transfers to the shareholder, the CRA is of the view that the shareholder gave consideration (the redeemed shares) to the corporation for the interest thus transferred. ...
Conference summary
5 October 2018 APFF Roundtable Q. 1, 2018-0768721C6 F - Procedure re: refund of excess w/h under Part XIII -- summary under Subsection 227(5)
After discussing the s. 214(16)(b) designation, CRA stated: [B]y virtue of the application of paragraph 214(16)(a) and any designation under paragraph 214(16)(b), the non-resident parent could therefore file, no later than two years after the end of each calendar year in which overpayments were made to the Receiver General, a Form NR7-R to recover these amounts, unless these amounts are applied … against amounts owing to or about to become due to Her Majesty in Right of Canada. ...
Conference summary
5 October 2018 APFF Roundtable Q. 1, 2018-0768721C6 F - Procedure re: refund of excess w/h under Part XIII -- summary under Paragraph 214(16)(b)
In its annual return it recognizes that by virtue of s. 18(4) the interest is non-deductible and is deemed to be a dividend – and with the Treaty-reduced rate of withholding being less that the rate at which Part XIII tax actually was withheld. ...
Conference summary
5 October 2018 APFF Roundtable Q. 8, 2018-0768791C6 F - Frais de repas -- summary under Subsection 8(4)
. … At the request of the APFF, the situation described in the statement of the question and the response of the CRA will be brought to the attention of that Department [of Finance]. ...
Conference summary
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 4, 2018-0765811C6 F - Tax on Split Income -- summary under Clause (c)(ii)(D)
(c)(ii)(D) – except that by virtue of s. (e)(i), the distribution would be an excluded amount if it was not derived directly or indirectly from a related business in respect of Jocelyne. ...
Conference summary
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F - Attribution rules and promissory note -- summary under Paragraph 74.5(2)(b)
It follows that … the exception provided for in subsection 74.5(2) could not apply. ...
Conference summary
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 12, 2018-0761581C6 F - Foreign Tax Credits related to mutual funds -- summary under Subsection 126(1)
. … In response to the expressed concern where a mutual fund is invested in a significant number of countries and the burden of allocating the respective information may be burdensome to the taxpayer, the CRA will revise its administrative position and request taxpayers to provide an amended tax slip that correctly reflects the federal foreign tax credit amounts claimed. ...
Conference summary
5 October 2018 APFF Roundtable Q. 16, 2018-0768871C6 F - Dépenses de bureau à domicile et d’automobile -- summary under Incurring of Expense
. … Where business expenses have been paid by someone other than the taxpayer carrying on the business, the amounts so paid could, depending on the circumstances, be included in the income of the taxpayer's business or give rise to the application of section 80. ...