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Ruling

2015 Ruling 2015-0573201R3 - Qualifying environmental trust

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling

2015 Ruling 2015-0573211R3 - Qualifying environmental trust

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling

2015 Ruling 2015-0573231R3 - Qualifying environmental trust

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 7. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling

2015 Ruling 2015-0573191R3 - Qualifying environmental trust

In May 2014, the NEB issued the MH-001-2013 Reasons for Decisions Set-aside and collection mechanisms (Pipeline Abandonment- Financial Issues) (the “SAM/COM Decision”), which required certain NEB-regulated pipeline companies to have a set-aside mechanism in place by January 1, 2015, and to begin accumulating funds to pay for pipeline reclamation. 4. ... Yours truly, XXXXXXXXXX Manager Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...
Ruling

2021 Ruling 2020-0875341R3 - post-mortem pipeline

Immediately prior to the time of the Deceased’s death, there were XXXXXXXXXX Opco Common Shares, XXXXXXXXXX Opco Class A Preference Shares, XXXXXXXXXX Opco Class B Preference Shares, XXXXXXXXXX Opco Class C Preference Shares, XXXXXXXXXX Opco Class D Preference Shares, XXXXXXXXXX Opco Class E Preference Shares, XXXXXXXXXX Opco Class F Preference Shares, XXXXXXXXXX Opco Class G Preference Shares, XXXXXXXXXX Opco Class A Special Shares and XXXXXXXXXX Opco Class B Special Shares, issued and outstanding, which were owned, and which had a FMV, ACB and PUC, as set forth below: Shareholder Number & Class FMV ACB PUC of Shares of Opco Deceased XXXXX Opco Common XXXXX XXXXX XXXXX Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class C XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class D XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class F XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Deceased XXXXX Opco Class A XXXXX XXXXX XXXXX Special Shares Deceased XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 1 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class G XXXXX XXXXX XXXXX Preference Shares Child 2 XXXXX Opco Class B XXXXX XXXXX XXXXX Special Shares Holdco XXXXX Opco Class E XXXXX XXXXX XXXXX Preference Shares On XXXXXXXXXX, Child2 transferred all of XXXXXXXXXX shares of Opco to a corporation controlled by Child2, in which the Estate has no interest. ... As a consequence, under subsection 70(5) of the Act, immediately before his death the Deceased was deemed to have disposed of the shares of Opco owned by him, and the Estate was deemed to have acquired such shares, at the FMV of such shares as set forth below: Number & Class of Shares of Opco FMV Immediately owned by the Deceased Before the Deceased Death XXXXX Opco Common Shares XXXXX XXXXX Opco Class A Preference Shares XXXXX XXXXX Opco Class B Preference Shares XXXXX XXXXX Opco Class C Preference Shares XXXXX XXXXX Opco Class D Preference Shares XXXXX XXXXX Opco Class F Preference Shares XXXXX XXXXX Opco Class G Preference Shares XXXXX XXXXX Opco Class A Special Shares XXXXX XXXXX Opco Class B Special Shares XXXXX 7. ...
Miscellaneous severed letter

23 January 1992 Income Tax Severed Letter 9130936 - Canadian Payroll Association (Round Table Questions)

However, in situations where security risks make it mandatory that the employee travel in a company- chauffeured vehicle, employees are not regarded as in receipt of a taxable benefit (IT-470R, par. 32);- Goods and Services Differential- Taxable (6(1)(b)), except for certain deemed residents (6(1)(b)(iii));- Hardship Allowance- Taxable (6(1)(a)), except for certain deemed residents (6(1)(b)(iii));- Relocation Allowance- if paid in a non-accountable manner, amounts in excess of $650 taxable (6(1)(b));- Reimbursement* of Moving Expenses- Not taxable where employee/family move to another establishment of the employer, or where employee/family move to accept employment with employer (IT-470R, par. 35). (* includes accountable advance) QUESTION #6 Are there any methods available that would allow an employee going on a foreign assignment the opportunity to defer compensation normally payable during the assignment until they return to Canada? ... Where an employee has become a non-resident of Canada while on foreign assignment his remuneration would only be taxable in Canada if it was in respect of services performed in Canada (ignoring the exceptional circumstances where paragraphs 115(2)(c) & (e) might apply). ...
Miscellaneous severed letter

23 October 1989 Income Tax Severed Letter AC74195 - Reporting Requirements Respecting Stripped Bonds

The following definitions are set out by Sloan and Zurcher in A Dictionary of Economics (4th ed) (New York: Barnes & Noble, Inc., 1968, at p. 34) A registered bond is recorded in the name of the owner. ... John Wiley & Sons: New York, 1978, at p. 375: a bond that is entered on the books of the issuing company in the name of the owner. ...
Miscellaneous severed letter

23 October 1989 Income Tax Severed Letter RCT 7-4195

The following definitions are set out by Sloan and Zurcher in A Dictionary of Economics (4th ed) (New York: Barnes & Noble, Inc., 1968, at p. 34) A registered bond is recorded in the name of the owner. ... John Wiley & Sons: New York, 1978, at p. 375 a bond that is entered on the books of the issuing company in the name of the owner. ...
Miscellaneous severed letter

25 April 1990 Income Tax Severed Letter RCT-0155

Aucun limite a la duree d'une position a decouvert Il n'y a pas de limite quant a la duree d'une position a decouvert tant que le courtier du vendeur peut emprunter une quantite equivalente de titres vendus a decouvert et que le vendeur maintient une couverture suffisante dans son compte a decouvert. (...) 5. ... No limit on duration of a short position There is no limit on the duration of a short position as long as the seller's broker can borrow an equivalent quantity of securities sold short and the seller maintains sufficient coverage in his short selling account. (...) 5. ...
Technical Interpretation - Internal

9 February 2022 Internal T.I. 2020-0873931I7 - Cover Letter - Mining Expenditure Review Table

Paragraph (f) of the definition of CEE. 23) Metallurgical testing Grinding or other physical tests performed on core sample and/or bulk sample Testing of the physical material of the deposit, on or off site. ... The CIM Definition Standards for Mineral Resources & Mineral Reserves (2014) are available at: https://mrmr.cim.org/en/standards/canadian-mineral-resource-and-mineral-reserve-definitions. ...

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