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Technical Interpretation - External
7 December 1999 External T.I. 1999-0006715 - Right to object and appeal
In the past, corporations would assign expected refunds of SR & ED investment tax credits or Film Tax Credits as security for bridge financing for their operations. ...
Technical Interpretation - External
2 February 2012 External T.I. 2012-0434311E5 - Canada-U.S. Tax Convention
Yours truly, for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal
23 April 2012 Internal T.I. 2011-0426601I7 - Part XIV tax - non-resident insurer
In this regard, form T2SCH 20, Part XIV – Additional Tax on Non- Resident Corporations is the schedule that computes the relevant amounts under subsection 219(1) of the Act. ...
Ruling
2007 Ruling 2006-0211991R3 - Part XIII Tax
Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - External
19 May 2009 External T.I. 2007-0263441E5 - Tax Treaties
Yours truly, Daryl Boychuk Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Technical Interpretation - Internal
20 November 2008 Internal T.I. 2008-0281411I7 - Addition of Beneficiaries
Robin Maley Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Conference
25 September 2012 Roundtable, 2012-0457611C6 - BC Tax Conference 2012 Question #5
In Interpretation Bulletin 83R3, Non-profit organizations Taxation of income from property, CRA has also take the position that rental income can be income from property or income from business, depending upon whether the rents were derived from one of the main activities of the club or ancillary to the activities of the club. ...
Technical Interpretation - External
20 November 2014 External T.I. 2013-0474101E5 - NPO wind-up - asset distribution
Messore (613) 948-2227 2013-047410 November 20, 2014 Dear XXXXXXXXXX: Re: Paragraph 149(1)(l) of the Income Tax Act and capital gains This is in response to your email interpretation requests regarding a client ("entity ") that considers its income to be exempt from income tax pursuant to paragraph 149(1)(l) of the Income Tax Act. ...
Technical Interpretation - Internal
23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit
British Columbia (Interior Tree Fruit & Vegetable Committee of Direction) (1930); Yates v.R. (2001), 2001 CarswellNat 1369 (T.C.C. ...
Ruling
2015 Ruling 2015-0570291R3 - Foreign tax credit on income from a trust
Yours truly, XXXXXXXXXX For Director Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...