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Technical Interpretation - External
16 December 1998 External T.I. 9831815 - CHILD SUPPORT AMOUNTS PAYABLE
Reasons: See # 980652. Since the court order was made before May 1997, there is no “commencement day”, as defined in subsection 56.1(4) of the Act and the order falls under the old child support rules. ...
Technical Interpretation - External
13 January 1999 External T.I. 9813665 - CHARITABLE GIFTS TO A MUNICIPALITY
Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch Enclosures ...
Technical Interpretation - External
7 January 1999 External T.I. 9834035 - XXXXXXXXXX SPIN-OFF
The International Section has reviewed seventeen different foreign spin-offs from 1996 to date in response to queries from Canadian shareholders like yourself, including spin-offs done by GM, PepsiCo, Hanson and Dun & Bradstreet. ...
Technical Interpretation - External
24 March 1994 External T.I. 9331645 - QUALIFIED SMALL BUSINESS CORPORATION SHARES
We would also note that in Question # 49 at the 1986 Revenue Canada Round Table held at the Annual Conference of the Canadian Tax Foundation, the Department was asked the following question: If a partnership disposes of a capital asset and realizes a capital gain on the disposition, could a partner who is an individual resident in Canada use his lifetime capital gains exemption in respect of his share of the gain? ...
Technical Interpretation - External
31 March 1994 External T.I. 9333995 - RRIF-PERIODIC PENSION PAYMENT-US CONVENTION(U5-100-18)
File # 933399 Principal Issues: Whether periodic payments out of a RRIF are considered to be "periodic pension payments" under paragraph 2(a) of Article XVIII of the Canada-US Convention. ...
Technical Interpretation - External
5 April 1994 External T.I. 9336485 - CAP. GAINS EX. FARM PROP.
Principal Issues: Whether a personally owned property of a deceased spouse which was used in a farming operation but is not used by the surviving spouse in farming but is rented to arm's length tenants meets the definition of a "qualified farm property " as found in subsection 110.6(1) of the Act. ...
Technical Interpretation - External
26 April 1994 External T.I. 9333965 - CHARITIES MUST BE REGISTERED IN ORDER TO TAX EXEMPT
On page 7 of Budget Paper D entitled "Charities under the Income Tax Act ", which was tabled with the above Budget Speech, it is stated: "The legislation will require all charities to register with Revenue Canada, whether or not they wish to issue receipts, in order to obtain tax-free status. ...
Technical Interpretation - External
21 April 1994 External T.I. 9402335 - OVERSEAS EMPLOYMENT TAX CREDIT (7970-7)
FILE # 940233 Principal Issues: General enquiries on whether an employee qualifies for the OETC in various situations. ...
Technical Interpretation - External
19 April 1994 External T.I. 9407695 - GUARANTEED SHARES AND PUT OPTIONS
Sugg in the 1992 CTF conference had the following footnote with respect to FMV purchase agreements: " The explicit exceptions are contained in paragraph (f) of the taxable preferred share definition in subsection 248(1) and subparagraphs (a)(i) and e(i) of the short- term preferred share definition in subsection 248(1). ...
Technical Interpretation - External
6 June 1994 External T.I. 9335905 - CORPORATE GIFT OF A LIFE INSURANCE POLICY
Principal Issues: whether the donation of a whole life insurance policy to a charity will qualify as a gift where the donor retains the right to the accumulated dividends (see telephone call: the issue of whether the policy can be shared between charities was not really his question) Position TAKEN: no Reasons FOR POSITION TAKEN: Position taken in prior correspondence e55294 and IT-244R3 on the basis that it is a gift " with strings attached" in that the donor receives the benefit from the accruing value in the CSV of the policy A. ...