Search - 广东省2002政府工作报告 一小发展 金句

4 November 2002 External T.I. 2002-0158885 F- Alloc. of Safe Inc. & Disc. ... Prud'Homme (613) 957-8975 Le 4 novembre 2002 Madame, Objet: Demande d'interprétation technique concernant le paragraphe 55(2) de la Loi de l'impôt sur le revenu La présente est en réponse à votre lettre du 21 août 2002 dans laquelle vous nous avez demandé notre opinion concernant l'application du paragraphe 55(2) de la Loi de l'impôt sur le revenu (ci-après la " Loi ") dans une situation particulière donnée. ... Pour ce faire, les opérations suivantes seraient effectuées. c) Messieurs A et B procéderaient chacun à la création d'une société de gestion (ci-après " GESCO A " et " GESCO B "). ...

31 July 2002 Ministerial Correspondence 2002-0149214- MC FINES & PENALTIES 65302 BC LTD Unedited CRA Tags 18(1)(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 July 31, 2002 Dear XXXXXXXXXX: The Honourable Elinor Caplan, Minister of National Revenue, has asked me to reply to your letter of June 13, 2002, concerning the adverse impact of a decision of the Supreme Court of Canada, on the deductibility of fines and penalties, and whether the Income Tax Act will be amended as a result of the decision. ...

15 May 2002 External T.I. 2002-0105485- HEALTH & WELFARE TRUST Unedited CRA Tags 6(1)(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. ... Principal Issues: 1. whether rules in IT-85R2 will apply where no actuarial info, but the only money that will be transferred to the trust is money that will be payable in the trust in the same year to employees 2. whether H&W trust rules apply where 2-tiered trust Position: 1.yes 2. issue withdrawn Reasons: 1. pay-as-you go plans acceptable 2. no clear business necessity for an additional trust XXXXXXXXXX 2001-010548 Denise Dalphy, LL.B. (613) 941-1722 May 15, 2002 Re: Request for Technical Interpretation We are writing in reply to your letters dated September 5, 2001 and March 27, 2002 concerning proposed arrangements for a trust to fund certain employee benefits. ... However, as discussed in our (XXXXXXXXXX/Dalphy) telephone conversation of May 7, 2002, we will provide the following general comments. ...

18 January 2002 External T.I. 2001-0116185- ERRORS & OMISSIONS INSURANCE Unedited CRA Tags 9(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. ... January 18, 2002 Dear XXXXXXXXXX: Re: Tax Planning- Errors and Omissions Insurance We are writing in response to your letter dated December 24, 2001, wherein you requested our opinion on whether it would be beneficial from a tax perspective for you to purchase errors and omissions insurance for your business. ...

10 May 2002 External T.I. 2002-0133495- GIFTS & AWARDS Unedited CRA Tags 6(1)(a) 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. ... Young, CA May 10, 2002 Dear XXXXXXXXXX: Re: Gifts and Awards This is in reply to your letter of March 14, 2002, concerning whether the new policy on employer-provided gifts and awards would apply to long-service awards given by your company. ...

24 June 2002 Internal T.I. 2002-0147387- TRAVEL & VEHICLE EXP. SPECIAL DUTY PAY Unedited CRA Tags 8(1)(h) 8(1)(h.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. ... June 24, 2002 Income Tax Appeals HEADQUARTERS John Crowley James Gibbons, CGA Manager 2002-014738 Deduction of employment expenses for special duty pay We are responding to your memorandum dated June 14, 2002, concerning the deduction of reasonable travel and motor vehicle expenses by a police officer for travel between the police station and another location while on "special duty pay" (SDP). ...

23 January 2002 External T.I. 2001-0092005- TRUST & CAPITAL GAINS EXEMPTION Unedited CRA Tags 110.6(2) 104(21.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reading of the particular legislation in section 110.6 and section 104 of the Act. 2001-009200 XXXXXXXXXX Allan Nelson, C.M.A. (613) 443-7253 January 23, 2002 Dear XXXXXXXXXX: Re: Technical Opinion Request We are writing in reply to your letter to us dated July 4, 2001, wherein you asked us to comment on whether the beneficiaries can claim their enhanced capital gains deductions on the amount of the capital gain that is designated to them by a trust. ... An amount designated to a beneficiary under subsection 104(21) must reasonably be considered to be part of the amount included in the beneficiary's income for that year under any of the provisions referred to in ¶ 1 above (see also ¶ 3 above)... ¶ 6. ...

19 December 2002 External T.I. 2002-0171065- Arm's Length Purchase & Sale of Shares Unedited CRA Tags 39 80 12 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 2002-017106 December 19, 2002 Dear XXXXXXXXXX: Re: Arm's-Length Purchase and Sale of Shares of a Corporation This is in response to your letter dated September 24, 2002, wherein you requested our views on the application of certain provisions of the Income Tax Act ("the Act") in the following situation. ... To make such a request the advance income tax ruling must be submitted in accordance with the guidelines set out in Information Circular 70-6R5 dated May 17, 2002 ("IC 70-6R5"). ...

22 October 2002 External T.I. 2002-0161565- DIRECTOR & OTHER FEES Unedited CRA Tags 6(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Seidel (613) 957-2058 October 22, 2002 Dear XXXXXXXXXX: Re: Honorariums We are writing in response to your letter dated September 4, 2002, concerning the applicability of paragraph 6(1)(c) of the Income Tax Act (the "Act") to "honorarium" payments made to certain individuals. ... Subsection 5(1) of the Act states that "... a taxpayer's income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by the taxpayer in the year". ...

3 May 2002 External T.I. 2002-0127425- surface lease & principal residence Unedited CRA Tags 54 9 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. ... Position: 1. question of fact whether adjacent land can be considered part of principal residence- but- partial disposition may be recognized Reasons: 1. as per paragraphs 1 & 2 of IT-200- capital portion is treated as partial disposition; See also IT-120R5 paragraphs 15 &16 (land >1/2 hectare may qualify if zoning restrictions don't allow smaller lots) & paragraph 18 (re-partial disposition) Lena Holloway, CA XXXXXXXXXX 613-957-2104 2002-012742 May 3, 2002 Dear XXXXXXXXXX: Re: Surface Leases This is in reply to your letter dated March 7, 2002 regarding the receipt of payments pertaining to the first year of a surface lease granted on land. ...