Search - 广东省2002政府工作报告 一小发展 金句

8 November 2002 External T.I. 2002-0159465- CTF BUSINESS EXPANSIONS Unedited CRA Tags 44(1) 13(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Principal Issues: 2002 Canadian Tax Foundation Q & A regarding the Exchange of Property Rules and Business Expansions. ...

5 July 2002 External T.I. 2002-0135725- Provincial Residence Determination Unedited CRA Tags REG 2607 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Reasons: n/a XXXXXXXXXX 2002-013572 Eliza Erskine July 5, 2002 Dear XXXXXXXXXX: Re: Provincial Residence Determination for XXXXXXXXXX This is in reply to your letter to the Canada Customs and Revenue Agency's (the CCRA's) Winnipeg, Manitoba office of April 2, 2002, requesting an opinion on the provincial residence status of your clients XXXXXXXXXX, for provincial tax purposes. ... If you have further interpretative issues regarding residence status determinations, or if you have comments or questions with respect to IT-221R3, please write to the International & Trusts Division of this Directorate. ...

6 November 2002 External T.I. 2002-0132395 F- Robot Class 10 Catégorie 10 Unedited CRA Tags 20(1)(a) Class 10(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-013239 Marc LeBlond Le 6 novembre 2002 Monsieur, Objet: Catégorie 10 de l'annexe II du Règlement de l'impôt sur le revenu La présente est en réponse à votre fac-similé du 3 avril 2002 et à nos conversations téléphoniques (LeBlond/XXXXXXXXXX). ... Le robot fut acquis, soit en l'an 1999 soit en l'an 2000, à un prix de 7 000 $. ...

15 May 2002 External T.I. 2002-0139005- Provincial residence while abroad Unedited CRA Tags 250(3) Reg. 2600 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2002-013900 Eliza Erskine May 15, 2002 Dear XXXXXXXXXX: Re: Impact of Location of Storage Services on Residence Determination This is in reply to your facsimile of May 6, 2002, in which you asked us to explain what impact the location of the storage of a person's effects could have on the determination of that person's residence status for tax purposes. ... If you have further interpretative issues regarding residence status determinations, or if you have comments or questions with respect to IT-221R3, please write to the International & Trusts Division of this Directorate. ...

3 July 2002 External T.I. 2001-0112325- PREMIUMS RECEIVED BY ISSUES OF DEBT Unedited CRA Tags 9(1) 39(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Diguer July 3, 2002 Dear XXXXXXXXXX: Re: Premium received by the issuer on the issuance of a debt obligation This is in reply to your letter dated November 23, 2001, in which you request our views on the characterization of a premium received by the issuer of a debt obligation. ... Written confirmation of the tax implications inherent in particular transactions are given by this Directorate only where the transactions are proposed and are the subject matter of an advance ruling request submitted in the manner set out in Information Circular IC-70-6R5 dated May 17, 2002. ...

9 September 2002 External T.I. 2002-0136985- Interpretation of Thin Cap Terms Unedited CRA Tags 18(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Thomson September 9, 2002 Dear XXXXXXXXXX: Re: Interpretation of thin capitalization terms This is in reply to your letter of April 23, 2002 and your subsequent emails in which you ask for our interpretation of certain terms contained in subsection 18(4) of the Income Tax Act (the "Act"). ... Yours truly, Olli Laurikainen for Director International & Trusts Division Income Tax Rulings Directorate ...

29 October 2002 External T.I. 2002-0161185- MEANING OF COMMON-LAW Unedited CRA Tags 248(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... The fact that two individuals maintain separate residences would not, in and by itself, preclude a finding that they are in a conjugal relationship for purposes of the Act. 2002-016118 XXXXXXXXXX Karen Power, CA (613) 957-2082 October 29, 2002 Dear XXXXXXXXXX: Re: Meaning of "Common-Law Partner" We are writing in response to your letter of August 26, 2002, wherein you requested an advance income tax ruling with respect to the definition of "common-law partner" as defined in subsection 248(1) the Income Tax Act (the "Act"). ... This case was validated by the Supreme Court of Canada in M. v H ([1999] 2 S.C.R. 3, 46 R.F.L. (4th) 32) where the following was stated at paragraphs 59 and 60: " Molodowich v Penttinen (1980), 17 R.F.L. (2d) 376 (Ont. ...

29 April 2002 External T.I. 2001-0109805- FARM PARTNERSHIP-DEATH OF A PARTNER Unedited CRA Tags 99(1) 98(3) 98(5) 70(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2001-010980 Shaun Harkin, CMA April 29, 2002 Dear XXXXXXXXXX: Re: Technical Interpretation Request: Family Farm Partnership This is in reply to your letter of November 2, 2001 wherein you ask the following questions: 1) Could a new partnership comprised of a deceased partner's spouse and the remaining partner be considered a continuation of the original partnership so that one T2042, Statement of Farming Activities, could be prepared for the year when the following conditions exist? ... Subsection 98(3) of the Act states in part: "... a Canadian partnership has ceased to exist and all the partnership property has been distributed to persons who were members of the partnership immediately before that time so that immediately after that time each such person has, in each such property, an undivided interest that, when expressed as a percentage (in this subsection referred to as that person's "percentage") of all undivided interests in the property, is equal to the person's undivided interest, when so expressed, in each other such property... ...

11 July 2002 External T.I. 2001-0114045- 75(2) and an Alter Ego Trust Unedited CRA Tags 75(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch c.c. ...

30 January 2002 External T.I. 2001-0106695- Subs. 219(5.3);Article X of Canada-US Treaty Unedited CRA Tags 219(5.2) 219(5.3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... XXXXXXXXXX 2001-010669 Eliza Erskine Attention: XXXXXXXXXX January 30, 2002 Dear Sirs: Re: Interaction of Subsection 219(5.3) of the Income Tax Act (the "Act") with Article X of the Canada-United States Tax Convention (the "Convention") This is in reply to your facsimile of October 19, 2001, requesting our views with respect to whether paragraph 2 or paragraph 6 of Article X of the Convention would apply with respect to the Canadian withholding tax on a deemed dividend arising pursuant to subsection 219(5.3) of the Act. ... The collection is effected by deeming a dividend to have been paid to the non-resident insurer that is subject to withholding tax at a rate of 25 % under Part XIII of the Act. ...