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Technical Interpretation - External

13 June 2000 External T.I. 2000-0020095 - INDIAN EMPLOYMENT INCOME

You are a status Indian, registered # XXXXXXXXXX, who lives in XXXXXXXXXX. ...
Technical Interpretation - External

5 April 2000 External T.I. 2000-0014265 - CALU CONFERENCE - 5.110.6(14)

Applying this view to your questions, and assuming the requirements of subsection 110.6(15) are met, a) & b) When determining the QSBC status for the shares owned by Mr. ...
Technical Interpretation - External

16 June 2000 External T.I. 2000-0029195 - INDIAN INVESTMENT INCOME

You indicate that you are a status Indian, registered # XXXXXXXXXX, who worked on reserve or Category 1 Lands for XXXXXXXXXX. ...
Technical Interpretation - External

17 July 2000 External T.I. 2000-0010935 - partner information return

Because this "charging section" [subsection 220(2.1) of the Act] which permits the Minister to make such a waiver continues on to state that "... but the person shall provide the document or information at the Minister's request" [emphasis added], members of partnerships listed in paragraph 11 of IC 89-5R must file such a return if the Minister makes such a request. 2. ...
Technical Interpretation - External

9 August 2000 External T.I. 2000-0029185 - ESTATE DESIGNATES CHARITY AS BENEFICIARY?

Diguer CGA Attention: XXXXXXXXXX August 9, 2000 Dear Sir: Re: Section 118.1 of the Income Tax Act (Canada) This is in reply to your letter dated May 29, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views on whether a charitable organization which has been named as the sole residual beneficiary of an estate of a deceased taxpayer (the "Estate") could be treated by the Estate as an income beneficiary in regards to periodic payments received by the Estate under a fixed term annuity. ...
Technical Interpretation - External

13 September 2000 External T.I. 2000-0036825 - REPURCHASE OF DEBENTURES ON OPEN MARKET

Diguer CGA Attention: XXXXXXXXXX September 13, 2000 Dear Sir: Re: Repurchase of Debentures on the Open Market This is in reply to your facsimile dated July 11, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views on the tax consequences to a taxable Canadian corporation of a purchase, by it, of its debentures on the open market. ...
Technical Interpretation - External

4 October 2000 External T.I. 2000-0016945 - ASSIGN. OF AMOUNT PAYABLE

Prior to the introduction of subsections 220(6) and 220(7) of the Act, corporations would assign expected refunds of SR & ED investment tax credits or Film Tax Credits as security for bridge financing for their operations. ...
Technical Interpretation - External

31 October 2000 External T.I. 2000-0052995 - Film Credit - 95 year Distribution Agree

& 2. No, based on the facts as presented. Reasons: 1. Since the film is a treaty co-production, clause 1106(1)(a)(ii)(A) of the draft Regulations, at the definition of excluded production, does not apply to the film. 2. ...
Technical Interpretation - External

15 November 2000 External T.I. 2000-0018125 - MUNICIPAL OFFICES TRAVEL

XXXXXXXXXX 2000-001812 Cornelis Rystenbil, CGA Attention: XXXXXXXXXX November 15, 2000 Dear Madam: Re: Municipal Officer's Travel This is in your reply to your correspondence of March 28, 2000 in which you ask for our view on your belief that "... the travel between the trustee's ward and the regional office is not personal since the trustees are under statutory obligation to reside in their ward... ...
Technical Interpretation - External

6 October 2000 External T.I. 2000-0037905 F - Estate freeze trust

Les actions détenues par Monsieur X sont des actions ordinaires ayant un capital versé et un prix de base rajusté de 100 $. ...

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