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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"). ...
Technical Interpretation - External
19 October 2009 External T.I. 2008-0301881E5 F - Fiducie titulaire d'une police d'assurance-vie
La prime annuelle est de 10 000$ et le capital assuré est de 500 000 $. ...
Conference
10 October 2008 APFF Roundtable Q. 44, 2008-0285441C6 F - Accès au dossier du vérificateur
Une demande en vertu de la LAI entraîne des frais de 5,00 $. Dans certains cas, des frais supplémentaires peuvent être exigées. ...
Technical Interpretation - External
8 May 2008 External T.I. 2008-0267831E5 - FX gain, debt, amalgamation
OUR COMMENTS Interaction of subsection 80.01(3), subsection 80(1) "Forgiven amount" and paragraph 80(2)(k) Subsection 80(1) defines the term "forgiven amount", in part, as follows: " 'forgiven amount' at any time in respect of a commercial obligation issued by a debtor is the amount determined by the formula A- B Where A is the lesser of the amount for which the obligation was issued and the principal amount of the obligation, B is the total of, a) The amount, if any, paid at that time in satisfaction of the principal amount of the obligation,.... ...
Ruling
2008 Ruling 2008-0265631R3 - Amendment to a DSU Plan
The Corporation established "XXXXXXXXXX " (the "Plan") for the benefit of resident and non-resident Eligible Directors of the Corporation. ...
Technical Interpretation - External
16 July 2008 External T.I. 2007-0257021E5 - Article XXIX A (3) (LOB) of the Fifth Protocol
As a result, we are of the opinion that US Holdco satisfies paragraph 3 of Article XXIX A (LOB) and can benefit from the reduced rate of Canadian withholding tax in Article X of the Treaty, provided that US Holdco satisfies the conditions in Article X of the Treaty. for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling
2008 Ruling 2007-0234421R3 - distribution to the public
XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...