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Conference summary
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3 -- summary under Paragraph 212.3(18)(a)
. … See summary under s. 212.3(2). ...
Conference summary
28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3 -- summary under Subsection 212.3(2)
. … However…the amount of the deemed dividend would be equal to nil. …The deemed disposition and reacquisition of shares pursuant to paragraph 111(4)(e) would neither constitute a transfer of any property by the CRIC for purposes of paragraph 212.3(2)(a) nor would it constitute any of the other amounts referred to in subsection 212.3(2)(a). ...
Conference summary
5 October 2012 Roundtable, 2012-0453581C6 F - Somme payable - revenus de placements -- summary under Subsection 104(24)
CRA stated: [T]he acknowledgement of debt does not appear … to satisfy the conditions set out above. ...
Conference summary
16 June 2014 STEP Roundtable, 2014-0526581C6 - STEP CRA Roundtable - June 2014 - Q18 -- summary under Subsection 107(2.001)
As a prescribed form is not available for the election, a letter should be filed with the trust's … Return for the year the distribution occurs…. ...
Conference summary
26 November 2013 Annual CTF Roundtable, 2013-0493811C6 - Change in use -- summary under Paragraph 13(7)(a)
. … [T]he CRA will not be changing its general position on the change in use rules as currently presented in Interpretation Bulletins IT-102R2 and IT-218R. ...
Conference summary
26 November 2013 Annual CTF Roundtable, 2013-0493811C6 - Change in use -- summary under Paragraph 45(1)(a)
. … [T]he CRA will not be changing its general position on the change in use rules as currently presented in Interpretation Bulletins IT-102R2 and IT-218R. ...
Conference summary
28 November 2010 CTF Annual Roundtable, 2010-0384341C6 - Flow-through Shares -- summary under Flow-Through Share
28 November 2010 CTF Annual Roundtable, 2010-0384341C6- Flow-through Shares-- summary under Flow-Through Share Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Flow-Through Share flow-through unit Respecting whether CEE can be renounced under a unit flow-through share agreement in respect of the portion of the subscription price allocated to a warrant to acquire a share that is not a flow-through share, CRA stated: CEE can be renounced only in respect of the portion of the subscription price allocated to a warrant which represents a right to acquire a share that would be a flow-through share [as] pursuant to paragraph (b) of … "flow-through share," the amount of resource expenses that may be renounced under the agreement cannot exceed the amount of consideration received by the corporation for the flow-through share or the right to acquire the flow-through share…. ...
Conference summary
11 October 2013 APFF Roundtable, 2013-0493671C6 F - Testamentary trust beneficiary of inter vivos trust -- summary under Testamentary Trust
When asked " How will the CRA monitor to determine whether a testamentary trust is beneficiary of an inter vivos trust? ...
Conference summary
30 November 2010 Annual CTF Roundtable, 2010-0386391C6 - Branch Tax -- summary under Article 10
XXIX A(3)) – so that no such benefits would be available here as the earnings of the LLC are derived by individuals. ...
Conference summary
29 November 2011 Roundtable, 2011-0426361C6 F - Price adjustment clause and redemption of shares -- summary under Subsection 84(3)
Consequently … the taxpayer should include in the computation of the taxpayer’s income for the 2011 taxation year a dividend equal to the additional payment received in 2011. ...