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Technical Interpretation - External

29 July 2002 External T.I. 2002-0140205 - MEANING OF AIR PURIFIER

According to Merriam- Webster's Collegiate Dictionary (Tenth Edition) "purify" may mean "to make pure: as... to free from undesirable elements", " while The Concise Oxford Dictionary (Eight Edition), states that the term may mean to "cleanse or make pure. ...
Technical Interpretation - External

10 July 2002 External T.I. 2002-0143035 - SUPERFICIAL LOSS

With respect to a number of questions you submitted, please note that where fewer securities are acquired during the relevant period than were of disposed during the period or when fewer securities are left at the end of the period than were acquired during the period, the Canada Customs and Revenue Agency ("CCRA") administratively accepts that the amount of the superficial loss be determined by using the following algebraic formula: S/L = (Least of S, P and B)/S x L where S/L is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 60 day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...
Technical Interpretation - External

13 September 2002 External T.I. 2002-0146705 - REIMBURSEMENT OF TUITION

Principal Issues: Whether reimbursement of tuition fees would fall within the guidelines set out in ITTN 13 when the fees are XXXXXXXXXX % reimbursed after the employee has been with the employer for XXXXXXXXXX years following the course, and fully reimbursed after XXXXXXXXXX years.. ...
Technical Interpretation - External

7 October 2002 External T.I. 2002-0145205 - ARMS LENGTH BOARD AND CHARITABLE DESIGNATION

In addition to Interpretation Bulletin IT-419R, we have enclosed for your reference, CCRA Guide number RC 4108(E) "Registered Charities and the Income Tax Act ". ...
Technical Interpretation - External

8 November 2002 External T.I. 2002-0159465 - CTF BUSINESS EXPANSIONS

Principal Issues: 2002 Canadian Tax Foundation Q & A regarding the Exchange of Property Rules and Business Expansions. ...
Technical Interpretation - External

12 November 2002 External T.I. 2002-0129675 - Is a power of appointment subject to 70(5)

As stated in Oosterhoff's Text Commentary & Cases on Trusts, an instrument which purports to grant a power of appointment may be construed as creating a discretionary trust, a power of appointment or an outright gift. ...
Technical Interpretation - External

8 January 2003 External T.I. 2002-0173665 - SMALL BUSINESS CORP

On behalf of the Canada Customs & Revenue Agency ("CCRA"), we apologize for the delay in responding to your inquiry. ...
Technical Interpretation - External

14 January 2003 External T.I. 2002-0176785 - SUPERFICIAL LOSSES

The Canada Customs and Revenue Agency administratively accepts that the amount of the superficial loss may be determined by using the following algebraic formula: SL = (Least of S, P and B)/S x L where SL is the superficial loss, S is the number of items disposed at that time, P is the number of items acquired in the 61-day period, B is the number of items left at the end of period, and L is the loss on the disposition as otherwise determined. ...
Technical Interpretation - External

15 January 2003 External T.I. 2002-0178505 - SUPERFICIAL LOSS

Scenario 2: Items 1 & 2 are the same as in scenario 1 above. 3. Mr. ...
Technical Interpretation - External

11 February 2003 External T.I. 2002-0170755 - GUIDING AND OUTFITTING LICENSES

Principal Issues: Treatment of proceeds of sale / transfer of guiding and outfitting licenses. ...

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