Search - 哈尔滨到北京 公里数

For example, it seems to us that the XXX project (W/P 10-8 & 10-9) included field tests on a new product which appear to have involved XXXX which helped to optimize the design of the eventual new product. ...

Prepared by: ORIGINAL SIGNED BY Approved by: Chief Services, Public Utilities & Exempt Corporations Section Corporate Rulings Division. ...

Snider, Section Chief Specialty Rulings Advanced Audit & Investigations Directorate Training Programs Section S. ...

Dans l'arrêt Youngman (86 DTC 6584), les actionnaires bénéficiaient de l'usage exclusif d'une résidence d'un coût de tout près de 400 000 $. ...

Situation 4 (i) Opco was incorporated with all of its shares hating been issued to one trust as follows: Shareholder No. and Class of Shares Subscription Price Trust 200,000 Class A preferred 200,000 Trust 1,000 common $ 1,000 The Class A preferred shares are redeemable and retractable for $l each and bear a 7% non-cumulative dividend. ...

However, based on two previous decisions, (Thompson Constr'n & Vancouver Tug Boat) he felt constrained as a matter of consistency to treat boiler costs as capital. ...

Si l'on utilise la méthode du coût moyen pour déterminer le coût des actions, le PBR de chaque action pour le bénéficiaire serait de 167 667 $. ...

In this case, Partner A's ACB of its partnership interest at the time of admission of Partner 8 would be $10 million for purposes of allocating income, losses or C0GPE, as the case may be, not $ nil as suggested in the hypothetical situation. ...

., XXXXXXXXXX% copyrights and XXXXXXXXXX % trademarks). In general, where a contract provides for a payment subject to tax under paragraph 212(1)(d) and for a payment that is not otherwise subject to part XIII tax under the Act, the onus is on the CRA to determine which portion of the payment is subject to tax. ...

More specifically, in technical interpretation 9203965 our Directorate stated: “... it is our view that where a corporation acquires shares of a wholly-owned subsidiary and the proceeds from the issue constitute permanent capital of the subsidiary such shares would not generally be considered to have been acquired in the ordinary course of the parent corporation's business…” In Canada v. ...