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Technical Interpretation - External

5 March 2010 External T.I. 2010-0355841E5 - Canada-PEI Business Development Programs

March 5, 2010 James Atkinson CGA XXXXXXXXXX (519) 457-4832 2010-035584 Attention: XXXXXXXXXX Re: Canada-PEI Business Development Programs: Self-Assessment, Financials, Planning & Skills This is in response to your email dated January 28, 2010 concerning the above named programs. ...
Ruling

2010 Ruling 2009-0352121R3 - Status of 149(1)(l) entity created by a Charity

Our understanding of the relevant definitions, the facts, the proposed transactions and their purpose are as follows: DEFINITIONS "Act" means the Income Tax Act (Canada) (R.S.C. 1985, 5th Supplement, c.1, as amended); XXXXXXXXXX; and "Charity" means "XXXXXXXXXX ", incorporated pursuant to letters patent issued under the Canada Corporations Act dated XXXXXXXXXX. ...
Technical Interpretation - Internal

3 August 2010 Internal T.I. 2010-0369281I7 - Clergy residence deduction

It is our understanding that the mission of the Entity is "XXXXXXXXXX " In Zylstra Estate v The Queen, 94 DTC 6687, Mackay, J. made the following comments when concluding why The Ontario Bible College and Ontario Theological Seminary ("OBC") and the Institute of Christian Studies ("ICS") were not considered a religious order for the purpose of claiming a clergy residence deduction pursuant to paragraph 8(1)(c): "There are two principal considerations which lead me to conclude that neither OBC nor ICS is a "religious order" within the intention of paragraph 8(1)(c). ...
Ruling

2010 Ruling 2010-0372181R3 - Canada-U.S. Tax Convention - Article IV(7)(b)

The Predco Debt is denominated in U.S. dollars and pays interest at a rate of XXXXXXXXXX % per annum. ...
Technical Interpretation - Internal

20 April 2010 Internal T.I. 2010-0355231I7 - Clergy residence deduction

The Entity's work involves "XXXXXXXXXX ". Its mandate is "to bring hope to the hungry, hurting and homeless through showing the love of God through word and deed". ...
Technical Interpretation - External

20 October 2015 External T.I. 2015-0574241E5 - Payments to First Nation (XXXXXXXXXX) Elders

Burke, 76 DTC 6075 (FCTD), the judge noted that “… the expression ‘superannuation fund or plan’ is broad enough to include any fund or plan for providing payments to persons who have by reason of age or disability ceased to be employed either entirely or in a particular position and whether or not the fund or the payments are provided at the expense of the employer or former employer.” ...
Technical Interpretation - Internal

2 April 2009 Internal T.I. 2008-0302631I7 - CCA Recapture and Cash Basis Taxpayer

The reasons given by the Taxpayer's wife in January 2009 for the conclusion by the Taxpayer that the debt became bad at the end of XXXXXXXXXX were as follows: (1) the Purchaser was the "XXXXXXXXXX " brother of the Taxpayer; (2) the Taxpayer did not want to cause distress or duress to his family, and especially his father; (3) mad cow disease was becoming a problem in Western Canada; and (4) the Taxpayer did not want to spend money on trying to collect at that point. ...
Technical Interpretation - Internal

8 April 2009 Internal T.I. 2009-0310621I7 - Clergy Residence Deduction

8 April 2009 Internal T.I. 2009-0310621I7- Clergy Residence Deduction Unedited CRA Tags 8(1)(c) Principal Issues: Is a rabbi, who is employed in XXXXXXXXXX, a Jewish school, considered to minister a congregation for the purpose of the deduction pursuant to paragraph 8(1)(c) of the Income tax Act (the "Act") Position: No Reasons: Giving lectures on religion and providing counselling service to a group of students is not considered to be "in charge of " or "ministering a congregation" for the purpose of deduction provided in paragraph 8(1)(c) of the Act April 8, 2009 XXXXXXXXXX TSO HEADQUARTERS Office Audit Section V. ...
Technical Interpretation - External

16 July 2009 External T.I. 2009-0313821E5 - Eligible apprentice

The Definition reads as follows: " "eligible apprentice" means an individual who is employed in Canada in a trade prescribed in respect of a province or in respect of Canada, during the first twenty-four months of the individual's apprenticeship contract registered with he province or Canada, as the case maybe, under an apprenticeship program designed to certify or license individuals in the trade;" Quebec- the CCQ In Quebec, apprentices in the construction trades are required to be registered as apprentices with the CCQ. ...
Technical Interpretation - Internal

25 August 2009 Internal T.I. 2009-0310861I7 - 149(1)(l)--Distribution to Members on Winding-Up

You advised that you are satisfied that the "XXXXXXXXXX " (the "Association") qualifies as an entity described in paragraph 149(1)(l) of the Income Tax Act (the "Act"). ...

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