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Article Summary
Martin Marcone, "Resolution Procedures for Intergovernmental Transfer Pricing Disputes: Part 2", 23 Can. Current Tax", Volume 23, Number 12, September 2013: -- summary under Article 26
. …] However, as indicated above, a precondition to arbitration is that a court in either country has not ruled upon the unresolved issues. ...
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Peter Megoudis, "The Canadian Non-resident Trust Rules and Global Employee Benefit Plan Trusts", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24, No. 3, October 2012, p. 1583. -- summary under Subsection 94(3)
. … It may be reasonable to view the custodian's holding of investment shares as an agency or bare nominee arrangement, and its holding of matching shares as more closely resembling that of a trust. ...
Article Summary
Ian Bradley, Ken J. Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231 -- summary under Subsection 91(4.7)
Buttenham, "The New Foreign Tax Credit Generator Rules", International Tax Planning, Volume XVIII, No. 2, 2012, p. 1228, at 1231-- summary under Subsection 91(4.7) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(4.7) After referring to the expansion of the income test in s. 91(4.1)(a) by virtue of the deductible dividend test in s. 91(4.7), they stated: … On this basis, the income test could apply to investments that may not be considered hybrid instruments in the conventional sense. ...
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Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Tangible Personal Property
. … If there is a large degree of affixation, the good either becomes incorporated into the real property as an improvement to the real property or it becomes affixed machinery. ...
Article Summary
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Investment
[T]he CRA has given an example [fn 34: … 2009-0309281E5 …example 4)] illustrating how the possibility of publicly traded common I shares being characterized as an investment for the purposes of the SIFT rules would be reduced if, among other factors, the corporation is a large corporation with other sources of income; the partnership earnings represent a relatively small component of the corporation's business; and the partnership interest is not exchangeable for shares of the corporation. ...
Article Summary
Mark D. Brender, Marc Richardson Arnould, Patrick Marley, "Cross-Border Cash-Pooling Arrangements Involving Canadian Subsidiaries: A Technical Minefield", Tax Management International Journal, 2014, p. 345. -- summary under Subsection 247(2)
[fn 6: … 2003-0033891E5] This statement is not to be taken to mean that there is an automatic exemption from the transfer pricing rules because of the mere existence of a specific provision that targets certain intra-group financing arrangements in a cross-border context; rather, the more specific provisions should be applied first and, if they do not apply, the application of the transfer pricing rules should be considered. ...
Article Summary
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66. -- summary under Paragraph 212.3(25)(b)
. … If a CRIC owned by a limited partnership is considered to be controlled by the general partner, the FA dumping rules could produce unexpected results. ...
Article Summary
Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1 -- summary under Paragraph 81(1)(c)
[fn 20: The Branch Exemption found in paragraph 81(l)(c) only provides that the international shipping income earned by the foreign taxpayer is not subject to Canadian income tax – it does not provide that the company is not carrying on business in Canada….]… For a large international shipping company with significant employees in Canada, this result could mean filing hundreds of nil returns...each year. ...
Article Summary
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- summary under Section 224.1
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Section 224.1 Summary Under Tax Topics- Income Tax Act- Section 224.1 Limitations on CRA compensation (set-off) rights (p. 13:36) While Revenu Québec followed the decision in DIMS Construction [fn 111: … 2005 SCC 52] with regards to formal bankruptcies, until quite recently it continued to apply the compensation mechanism to use post-insolvency refunds owed to the tax debtor to reduce pre-insolvency debts when the debtor was the subject of an approved proposal under the BIA. ...