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Article Summary
Manal Corwin, Jesse Eggert, "Understanding the Operation, Impact, and Practical Implications of the MLI", Tax Management International Journal, Vol. 46, No. 8, 11 August 2017, p. 407 -- summary under Article 13
.] … Principal purpose test can be applied to avoidance of permanent establishment even if only one Treaty (“CTA”) adopts MLI Art. 13 (pp. 414-5) [E]ven where only one party to a CTA adopts provisions expanding the PE article, it may have effect under the domestic law of a source country if that country invokes the PPT to deny treaty protection. ...
Article Summary
Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper -- summary under Subparagraph 212.3(1)(a)(ii)
Example of application of s. 212.3(1)(a)(ii) to loan made by 9% shareholder of (factually NAL) Canco (held by NR Parent) to a CFC held by Canco (p. 6) [T]he CRIC and NR Parent [holding 9% and 91% of the shares of Canco1, which holds the subject corporation] deal at arm’s length, but … the CRIC does not deal at arm’s length with Canco1 due to factual circumstances…. ...
Article Summary
Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper -- summary under Paragraph 212(3.6)(a)
. — One possibility is that these are orphaned references from the prior version of these provisions, as there is no longer a reference to "particular time" in subsection 212(3.6). ...
Article Summary
John Tobin, "Infrastructure and P3 Projects", 2017 Conference Report (Canadian Tax Foundation), 10:1-31 -- summary under Paragraph 96(2.2)(d)
[I]n another technical interpretation, [fn 28: … 9301835] the CRA stated that non-recourse debt obtained by a partnership that arose as a result of legitimate commercial transactions unrelated to a general partner’s acquisition of a partnership interest would not generally be considered to be an amount granted for the purpose of reducing the partner’s loss from being a partner. ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Majority-interest group of beneficiaries
. … …The unitholders' investments are managed on a discretionary basis. ...
Article Summary
Tim Fraser, Jim Samuel, "The Preacquisition Surplus Election: More Than Meets the Eye?", Canadian Tax Journal (2021) 69:2, 595 - 627 -- summary under Paragraph 93(1.1)(b)
If Canco instead elects, the $100 million dividend is treated as having been paid from preacquisition surplus, triggering a $50 million gain – but s. 93(1.1)(b) then applies to recharacterize a portion of that gain as a distribution from taxable surplus. ...
Article Summary
Joint Committee, "Section 116 of the Income Tax Act", 24 January 2025 Joint Committee submission to the Assistant Commissioner of the Compliance Programs Branch of CRA -- summary under Subsection 116(5)
That, where CRA has determined that the subject property is not TCP, it issue a s. 116 certificate on that basis, rather than a letter stating that it cannot issue a certificate because the property is not TCP (the certificate could be issued on the basis that no Canadian income tax is owing on the disposition) – or, failing that, publish a position that such a “No-TCP” letter releases the purchaser from liability. ...
Article Summary
Glen Loutzenhiser, "Sham in the Canadian Courts", Sham Transactions (Edwin Simpson and Miranda Stewart, editors), Oxford University Press, 2014. -- summary under Sham
. … [T]he court held the transaction was not a sham because it was not constructed to create a false impression-the appearance created by the documentation was the reality…. ... Noël JA concluded that on that basis the filings were a sham. … The classic Snook formulation of a sham requires a common intention that the acts or documents are not to create the legal rights and obligations which they give the appearance of creating. ...
Administrative Policy summary
23 March 2017 CBA Commodity Taxes Roundtable, Q.19 -- summary under Supporting Documentation
. … If an attempt is made to remedy the [described] situation by obtaining an amended invoice in compliance with the disclosure requirements, then the CRA will accept the amended invoice as supporting documentation. With respect to the letter from the supplier … [p]aragraph (h) … includes “any other document validly issued or signed by a registrant in respect of a supply made by the registrant on which GST/HST is paid or payable”. ...
Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 265(8)
Example showing dealer responsibility for nominee-name accounts and dealer/fund duty division re client-name accounts 5.15 … Example – Identification and reporting on an interest in a fund Two U.S. residents, Investor A and Investor B, seek to invest in Mutual Fund ABC (referred to in this example as the "Fund"). ...