Search - 哈尔滨到北京 公里数

You have requested our comments on how WGTP payments to landowners are to be treated for purposes of the Income Tax Act as, in order to determine eligibility for the GIS, your Act states: "the income for a calendar year of a person or an applicant is the income of that person or applicant for that year computed in accordance with the Income Tax Act ". ...

Reasons: Paragraphs 88(1)(e.2) & 87(2)(l) provide that when a wholly-owned sub is wound-up into its parent, the parent is considered the same company as the sub for purposes of section 37 and therefore for paragraph 12(1)(v). 5-952037 XXXXXXXXXX Franklyn S. ...

Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 2- ...

Principal Issues: What is the "amount paid" within the meaning of the term "forgiven amount" where debt of a partnership is settled in exchange for an interest in the partnership Position: Equal to the amount of cash the partnership would be entitled to receive on the admission of a new partner but gave up in return for a settlement of the obligation Reasons: Case law / use of words "amount paid", and not "amount or value received" 2003-002581 XXXXXXXXXX Denise Dalphy, LL.B. (613) 941-1722 September 3, 2003 Dear XXXXXXXXXX: Re: Issuance of Partnership Units in Settlement of Debt We are writing in reply to your letter dated June 18, 2003 wherein you requested our views on income tax consequences where a commercial debt obligation of a partnership is settled by the issuance of partnership units to the former creditor. ...

We also acknowledge our conversations (Young / XXXXXXXXXX) of November 13, 2003, and January 30, 2004. ...

17 February 2004 External T.I. 2004-0061271E5- Share of family farm corporation Unedited CRA Tags 110.6(1) Principal Issues: Whether the general comments concerning the application of the definition of "share of the capital stock of a family farm corporation" in ITA 110.6(1) to Situation 1 described in file # 2001-0088115 are still valid today. ...

We also acknowledge our conversations (Young / XXXXXXXXXX) of March 4 and 9. ...

We also acknowledge our various telephone conversations (Young / XXXXXXXXXX) and your subsequent correspondence. ...

Position: YES Reasons: IT-522 par 9, fairness for cash basis employees who cannot use 18(9) to average out the up-front deduction, provided amount meets the 67.3 limitation if amount is averaged out and vehicle is within the other restrictions of the section ie $ 30,000 vehicle cost and $800 mo. lease. 2003-005179 XXXXXXXXXX C. ...

Lee Workman Financial Institutions Team Financial Industries Division Income Tax Rulings Directorate Policy & Planning Branch ...