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Miscellaneous severed letter
27 March 1992 Income Tax Severed Letter 9202125 - Remote location — minimum level of services
27 March 1992 Income Tax Severed Letter 9202125- Remote location — minimum level of services Unedited CRA Tags 6(6)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter
4 May 2001 Income Tax Severed Letter 2001-0066455 F - 15(2.4)(a)(c) / 84.1(1)(b)
4 May 2001 Income Tax Severed Letter 2001-0066455 F- 15(2.4)(a)(c) / 84.1(1)(b) Unedited CRA Tags 15(2), 15(2.4), 84.1(1)(b) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...
Miscellaneous severed letter
11 February 1986 Income Tax Severed Letter 7-0084 - []
11 February 1986 Income Tax Severed Letter 7-0084- [] DATE: February 11, 1986 TO- Provincial and International Relations Division FROM- Specialty Rulings Directorate Reorganizations and Non-Resident Division Alan Jane 993-7295 ATTENTION Mr. ...
Technical Interpretation - Internal
19 September 2023 Internal T.I. 2022-0950421I7 - Part-Year Resident - Federal Surtax & Prov Tax
19 September 2023 Internal T.I. 2022-0950421I7- Part-Year Resident- Federal Surtax & Prov Tax Unedited CRA Tags Subsections 2(1), 2(2), 2(3), sections 114, 115, subsections 120(1), 120(3), 120(4), section 250 of the Act, Regulation 2600, 2601(1), 2601(5)(a) Principal Issues: If an individual who is factually a resident of Canada ceases to be resident during the year, would the taxable capital gain arising from disposition of taxable Canadian property during the part of the year that the individual becomes non-resident be subject to federal surtax under subsection 120(1) of the Act or would it be subject to provincial income taxes? ...
Technical Interpretation - External
5 September 2024 External T.I. 2024-1019071E5 - Settlement monies & income tested benefits
5 September 2024 External T.I. 2024-1019071E5- Settlement monies & income tested benefits Unedited CRA Tags 81(1)(a) and 12(1)(c) of the Income Tax Act Principal Issues: 1. ...
Technical Interpretation - Internal
22 February 2002 Internal T.I. 2001-0101867 - Shareholder - Loans & 15(1)
22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1) Unedited CRA Tags 15(1) 56(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ...
Technical Interpretation - External
25 February 2025 External T.I. 2024-1043701E5 - Indian Act Tax Exemption & Employment Income
25 February 2025 External T.I. 2024-1043701E5- Indian Act Tax Exemption & Employment Income Unedited CRA Tags ITA para. 81(1)(a); IA s. 87 Principal Issues: Whether the employment income of certain employees is exempt under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act. ...
Administrative Letter
15 January 1998 Administrative Letter 9801082 - ICE STORM/VERGLAS Q & A, BUSINESS WINDOM/GUICHET AFFAIRE
15 January 1998 Administrative Letter 9801082- ICE STORM/VERGLAS Q & A, BUSINESS WINDOM/GUICHET AFFAIRE Unedited CRA Tags 2 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Business Window / Guichet d’affaires GST/HST-TPS/TVH Q Will late filing penalty and interest charges be imposed on a client who files his or her GST/HST return/installment late due to the ice storms which began January 6, 1998. ...
Ruling
30 November 1997 Ruling 9731503 - RELATED GROUP LOSS UTIL. & RECAPTURE DEFERRAL
& RECAPTURE DEFERRAL Unedited CRA Tags Reg 1101 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... The sale price and the cost amount of the assets to be sold are as follows: XXXXXXXXXX Sale Price Cost Amount Tangible Assets XXXXXXXXXX XXXXXXXXXX Goodwill & other intangibles XXXXXXXXXX XXXXXXXXXX 6. ...
Ruling
2018 Ruling 2018-0750471R3 - Non-qualifying amalgamation of NPO & public foundation
2018 Ruling 2018-0750471R3- Non-qualifying amalgamation of NPO & public foundation Unedited CRA Tags 15(1), 56(2), 87, 149, 149.1, 188(1), 246(1), 248(1) "shareholder" Principal Issues: (1) Whether two societies, a public foundation that is a registered charity and a non-profit organization, both established under the XXXXXXXXXX, be considered to have disposed of their assets on their amalgamation to create a new society? ... This letter amends the original advance income tax ruling letter dated XXXXXXXXXX, by amending paragraphs 16 and 38(b) and the “OTHER COMMENTS” section of this document to change the reference to “charitable organization” / “registered organization” to “public foundation” with respect to Entity 4/Amalco. ...