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Technical Interpretation - Internal summary
30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund -- summary under Subparagraph 152(4)(a)(i)
. … [S]ince the necessity to effect the circular calculation…is well known, we believe that a reasonable and prudent person would have effected the circular calculation in order to report (in the income tax return filed) the correct figures to the Minister. ...
Technical Interpretation - External summary
20 August 2015 External T.I. 2015-0581681E5 F - Non-resident trust rules -- summary under Connected Contributor
. … After paraphrasing the definitions of "resident contributor," "contributor" and "resident beneficiary" (which latter definition referenced a "connected contributor to the trust,") CRA stated: Under subsection 94(1), a "connected contributor" includes any contributor to the trust at a particular time other than a person all of whose contributions to the trust made at or before the particular time were made at a non-resident time of the person as defined in subsection 94(1). ...
Ruling summary
2014 Ruling 2013-0514561R3 - Payment in lieu of continued PHSP coverage -- summary under Paragraph 6(1)(a)
Proposed transactions Former employees (and dependants where relevant) will receive under a CCAA Plan one or more payments out of the available cash pool of Canco on account of their claim for termination of coverage under the Plans in an amount equal to their pro-rata share of the aggregate settlement amount – except that claims under a Life insurance plan will be paid separately. ...
Technical Interpretation - Internal summary
13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices -- summary under Subparagraph 6(1)(a)(i)
. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...
Technical Interpretation - Internal summary
23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization -- summary under Paragraph 149(1)(l)
" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...
Technical Interpretation - Internal summary
21 January 2013 Internal T.I. 2012-0442021I7 F - Assessing 163(2) penalty -- summary under Subparagraph 163(2)(a)(i)
. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...
Ruling summary
2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation -- summary under Paragraph 149.1(2)(a)
. … [T]he Charities Directorate…have advised us that… the performance of XX services by the Charity to Newco would be a business that is not a related business. ...
Technical Interpretation - External summary
30 April 2013 External T.I. 2013-0475271E5 F - CCTB - Marital Status Change -- summary under Paragraph 122.62(7)(b)
. … Mr. B's income will not be considered in setting the CCTB for the months before July 2012 since paragraph 122.62(7) (b) applies only to a month that begins after a change in marital status. ...
Technical Interpretation - External summary
21 August 2014 External T.I. 2014-0527611E5 - T1135 for Deceased Individual -- summary under Subsection 233.3(3)
This combined value should be included in Category 6 of Form T1135, " Other property outside of Canada. ...
Technical Interpretation - External summary
25 August 2015 External T.I. 2015-0571271E5 F - Affiliated Trusts under Paragraph 251.1(1)(h) -- summary under Contributor
X would also, by virtue of subparagraph 251.1(4)(d)(i), be a majority interest beneficiary of Trust B… … Trust A and Trust B would thus be affiliated…by virtue of subparagraph 251.1(1)(h)(i)…. ...