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Ruling

2006 Ruling 2005-0149101R3 - Amending trust indenture and subdividing units

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2004-0091961R3 - XXXXXXXXXX Indian reserve loan insurance arrangement

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2006 Ruling 2006-0189151R3 - Reasonableness Shareholder Manager Remuneration

. / Tax Services Social Insurance No. Office XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX The Tax Services Office for each Taxpayer is shown above. ...
Ruling

2006 Ruling 2006-0184571R3 - Loss utilization in related companies

By directors' resolution Holdco will authorize the issuance of a new series of preferred shares (the "Holdco Preferred Shares") with the rights and restrictions as follows: (a) non-voting; (b) annual cumulative dividend rate equal to the Opco Subordinated Rate + XXXXXXXXXX%; (c) redeemable for an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; (d) retractable for an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; (e) dividends and proceeds on winding up or dissolution rank ahead of any payment on shares ranking junior; (f) on winding up or dissolution, holders will receive an amount equal to the aggregate of the amount for which the shares were issued and any unpaid dividends; and (g) will be automatically retracted three days prior to any bankruptcy or insolvency of Holdco. 10. ...
Ruling

2006 Ruling 2006-0202101R3 - Incorporating a XXXXXXXXXX Practice

Approximately XXXXXXXXXX % of the Partnership Revenue is generated through XXXXXXXXXX services XXXXXXXXXX. ...
Ruling

2007 Ruling 2006-0208571R3 - Entity Classification

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...
Ruling

2004 Ruling 2004-0099081R3 - XXXXXXXXXX

Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Ruling

2005 Ruling 2005-0139621R3 - Loss Utilization

Quarterly, C Co will pay a dividend of $XXXXXXXXXX ($XXXXXXXXXX ÷ XXXXXXXXXX) to B Co. ...
Ruling

2005 Ruling 2005-0140221R3 - Disposition of Taxable Canadian Property

Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...
Ruling

2005 Ruling 2005-0143221R3 - exploration/new mine- CEE

On XXXXXXXXXX, 2005, a favourable advance income tax ruling (our file # 2004-010307) was issued concerning expenses qualifying under paragraph (f) of the definition of CEE related to proposed exploration drilling programs to be undertaken on three other zones on the Property. ...

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