Search - 哈尔滨到北京 公里数

.), c.1, as amended (the "Act"); (b) "ACB" means "adjusted cost base" as that expression is defined in section 54 and subsection 248(1); (c) "arm's length" has the meaning assigned by subsection 251(1); (d) "BCA" means the Business Corporations Act XXXXXXXXXX as amended; (e) "capital property" has the meaning assigned by section 54; (f) "cost amount" has the meaning assigned by subsection 248(1); (g) "disposition " has the meaning assigned by section 54; (h) "financial institution" has the meaning assigned by subsection 142.2(1) (i) "ineligible property" has the meaning assigned by paragraph 88(1)(c); (j) "investment dealer" has the meaning assigned by subsection 142.2(1); (k) "mark-to-market property" has the meaning assigned by subsection 142.2(1); (l) "PUC" means paid-up capital as that expression is defined in subsection 89(1); (m) "registered securities dealer" has the meaning assigned by subsection 248(1); (n) "proceeds of disposition" has the meaning assigned by section 54; (o) "public corporation" has the meaning assigned by subsection 89(1); (p) "related persons" has the meaning assigned by subsection 251(2); (q) "safe income on hand" in respect of particular shares of a corporation at a particular time refers to the income earned or realized, within the meaning of paragraphs 55(5)(b) or (c), by any corporation after 1971 and before the safe-income determination time to the extent that it is on hand and can reasonably be considered to contribute to the capital gain that would be realized on a disposition at fair market value of the particular share of the corporation; (r) "safe income determination time" has the meaning assigned by subsection 55(1); (s) "stated capital" has the meaning assigned by XXXXXXXXXX of the BCA; (t) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); and (u) "taxable Canadian corporation" has the meaning assigned by subsection 89(1). ...

(iii) OPCO devra payer à PUBLICO des redevances annuelles correspondant au plus élevé de: (a) XXXXXXXXXX $ et (b) coût de maintien des marques de commerce plus XXXXXXXXXX%. ...

Reasons: (1) Ruling granted previously in similar circumstances- transaction not to confer benefit – in particular, transaction at less than FMV permitted tax deferred transaction with restriction of ACB of the foreign affiliate shares to amount of the transfer. (2) The transactions are not a misuse or abuse of the Act or its provisions. (3) The “one of the main purposes” condition has not been met. ...

2020 Ruling 2020-0860231R3- Post-mortem planning Unedited CRA Tags 84(2), 84.1, 88(1), 245(2) * Principal Issues: Post-mortem pipeline and bump transaction ruling Position: Favourable rulings issued. ...

As such, F’s deemed proceeds of disposition were $XXXXXXXXXX, pursuant to subparagraph 70(6)(b)(ii), resulting in $ XXXXXXXXXX capital gain for F’s XXXXXXXXXX taxation year. ...

XXXXXXXXXX 2020-086244 XXXXXXXXXX Dear XXXXXXXXXX: Re: CONTAINS TAXPAYER INFORMATION Advance Income Tax Ruling – Subsection 84(2) and Charitable donation XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX in which you requested an advance income tax ruling (“Ruling”) on behalf of the above-named taxpayers. ...

XXXXXXXXXX 2021-088901 XXXXXXXXXX, 2021 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – Redemption of Mutual Fund Trust Units Held by Registered Plans XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX requesting an advance income tax ruling (“Ruling”) on behalf of the above-named Taxpayer. ...

The number and classes of such shares and their FMV immediately before the Deceased’s death were as follows: Type of shares Class # of shares FMV Common Class 1 XXXXXXXXXX XXXXXXXXXX Common Class 2 XXXXXXXXXX XXXXXXXXXX Special Class A XXXXXXXXXX XXXXXXXXXX Special Class B XXXXXXXXXX XXXXXXXXXX Special Class C XXXXXXXXXX XXXXXXXXXX 6. ...

Step 9 – there is no non-resident vendor and the purchaser is Taxpayer 6 for the acquisition of all issued and outstanding common shares of Taxpayer 11. 21. ...

The tax attributes attached to the shares of Opco immediately before the Deceased’s death were as follows: Shareholder Number & Class of FMV ACB PUC Shares of Opco Deceased XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class E Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class F Special Shares XXXXX XXXXXX XXXXX Deceased XXXXX Opco Class Z Special Shares XXXXX XXXXXX XXXXX Child 1 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 2 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 5 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 6 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX Child 7 XXXXX Opco Class A Common Shares XXXXX XXXXXX XXXXX 7. ...