Search - 广东省2005政府工作报告 一小发展 金句

2005 Ruling 2005-0125481R3 F- Cotisation syndicale Unedited CRA Tags 8(1)(i) 8(5)(c) Principales Questions: Est-ce qu'une cotisation syndicale versée pour financer des activités de formation syndicale sera déductible en vertu du sous-alinéa 8(1)(i)(iv) de la Loi. ... Chaque XXXXXXXXXX a établit une caisse XXXXXXXXXX (ci-après "Caiss "), conformément aux disposition des conventions collectives XXXXXXXXX, afin de comptabiliser les cotisations reçues des salariés en vertu de la clause XXXXXXXXXX de leur convention collective (ou l'équivalent de cette clause). 11. ... La cotisation de XXXXXXXXXX $ de l'heure travaillée doit être payée par chaque salarié oeuvrant dans les secteurs XXXXXXXXXX. 15. ...

2005 Ruling 2005-0146031R3- ATR-Deduct. of Shareholder/Manager Remuneration. ... XXXXXXXXXX 2005-014603 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request- XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling in respect of the above-noted company as it pertains to the deductibility of shareholder/manager remuneration. ... The shareholdings of the Corporation are as follows: Share Common % Preferred % Shareholders Class Shares Shares Shareholder A Class A XXXXXX XXXXXXXX XXXXXXXXXX XXXXXXXXXX Class B XXXXXX XXXXXXXX XXXXXXXXXX XXXXXXXXXX Shareholder B Class B XXXXXXXXXX XXXXXXXXXX Shareholder C Class A XXXXXX XXXXXXXX XXXXXXXXXX XXXXXXXXXX Class B XXXXXX XXXXXXXX XXXXXXXXXX XXXXXXXXXX Shareholder D Class B XXXXXXXXXX XXXXXXXXXX Total XXXXXX XXXXXXXX XXXXXXXXXX XXXXXXXXXX 13. ...

2005 Ruling 2005-0144741R3- Withholding tax; interest Unedited CRA Tags 212(1)(b)(vii) 245(2) Principal Issues: Request for minor amendments to the facts and proposed transactions described in the Ruling. ... XXXXXXXXXX 2005-014474 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your facsimile dated XXXXXXXXXX in which you requested amendments to the facts and proposed transactions set out in the Advance Income Tax Ruling letter (document # 2005-011909) issued to the above-referenced taxpayers on XXXXXXXXXX, 2005 (the "Ruling"). ...

2005 Ruling 2005-0155811R3- Disposition of Taxable Canadian Property Unedited CRA Tags 116(1) Article IV of Canada-US Treaty Article XIII of Canada-US Treaty Principal Issues: Whether paragraph 4 of Article XIII of the Canada-US Treaty will apply to the disposition of taxable Canadian property (shares) by a US partnership that has elected to be treated as a corporation for US income tax purposes. ... XXXXXXXXXX 2005-015581 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling- 2005-014022 This is in response to your XXXXXXXXXX request for amendments to advance income tax ruling #2005-014022, which was issued on XXXXXXXXXX, 2005 (the "Ruling"). 1. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2005-0117902R3- Additional Ruling Unedited CRA Tags 80 132.2 253.1 132(6) Principal Issues: Statements added for greater clarity. ... XXXXXXXXXX 2005-011790 XXXXXXXXXX, 2005 Dear Messrs: Re: Advance Income Tax Ruling XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) XXXXXXXXXX (XXXXXXXXXX Tax Services Office, XXXXXXXXXX Taxation Centre) This is in reply to our conversation dated XXXXXXXXXX in which you requested amendments to the rulings set out in the Advance Income Tax Ruling letter (document # 2005-011790) issued to the above-referenced taxpayers on XXXXXXXXXX 2005 (the Ruling). ...

2005 Ruling 2004-0109391R3- Supplemental Ruling Unedited CRA Tags 88(1)(d.3) 88(1)(c.2) 73(1) 118.1 Principal Issues: Minor changes to facts in ruling. ... XXXXXXXXXX 2004-010939 XXXXXXXXXX, 2005 Dear Sir: Re: Supplemental Advance Income Tax Ruling Request XXXXXXXXXX (the "Taxpayers") Further to your letter of XXXXXXXXXX, the following amendments are made to advance income tax ruling 2004-006027 that was issued to the Taxpayers on XXXXXXXXXX, 2004 (the "Ruling"): (a) paragraph 1(v) of the DEFINITIONS is deleted; (b) the references to "GCO", "XXXXXXXXXX Class G Preference" shares and "XXXXXXXXXX Class H Preference" shares in paragraph 4 are deleted; (c) the reference to "XXXXXXXXXX Class C Preference" shares in paragraph 4 of the Ruling is deleted and replaced with a reference to "XXXXXXXXXX Class E Preference" shares; (d) paragraph 5 is deleted; (e) paragraph 6 of the Ruling is deleted and replaced with " XCO is the sole shareholder of a number of subsidiary companies (the "Subsidiaries"), the shares of which are held by XCO as capital property for the purposes of the Act (the "Subsidiary Shares"); (f) the reference to "GCO," in paragraph 14 is deleted; (g) paragraph 48 is deleted; and (h) paragraph 1(d) of the COMMENTS is deleted and replaced with "any tax consequences relating to the facts and the proposed transactions described herein other than those described in the rulings given above". ...

2005 Ruling 2005-0117641R3- Loss Utilization Unedited CRA Tags 20(1)(c) 112(1) 80(1) 245(2) Principal Issues: A loss utilization within an affiliated group of corporations where profitcos are partners in an LP. Position: acceptable Reasons: Paragraph 32 of IT-533 XXXXXXXXXX 2005-011764 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX ("A Co")- (XXXXXXXXXX) XXXXXXXXXX ("LP") This is in reply to your letter of XXXXXXXXXX, wherein you request an advance income tax ruling on behalf of the above named taxpayers. ... As at the end of its last fiscal year ending on XXXXXXXXXX, the balance of non-capital losses of A Co amounted to $XXXXXXXXXX, which is the sum of its operating losses incurred in the following taxation years: XXXXXXXXXX $ XXXXXXX (Loss subject to subsection 111(5)) XXXXXXXXXX $ XXXXXXX $ XXXXXXX It is expected that A Co will continue to be in a loss position for the fiscal year ended on XXXXXXXXXX. 4. ...

2005 Ruling 2004-0109481R3- Loss Consolidation Unedited CRA Tags 85(1)(g) 191(2) 20(1)(c) Principal Issues: Whether loss utilization within affiliated group of companies is acceptable. Position: Yes XXXXXXXXXX 2004-010948 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX ("Lossco") XXXXXXXXXX ("Profitco") XXXXXXXXXX ("Cco") Advance Income Tax Ruling Request We are writing in response to your letter of XXXXXXXXXX in which you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... As at XXXXXXXXXX, Lossco's non-capital losses were as follows: Year of Expiry Amount XXXXXXXX $ XXXXXXXX XXXXXXXX $ XXXXXXXX XXXXXXXX $ XXXXXXXX XXXXXXXX $ XXXXXXXX XXXXXXXX $ XXXXXXXX Total $ XXXXXXXX Lossco's taxable income in respect of its XXXXXXXXXX taxation year is sufficient to utilize the non-capital loss of $XXXXXXXXXX that would otherwise have expired in XXXXXXXXXX. ...

2005 Ruling 2005-0133041R3- Investors not dealing non-arm's length Unedited CRA Tags 248(1) taxable Canadian property 251(1)(c) Principal Issues: Whether Investors that collectively own XXXXXXXXXX % of a Canadian corporation are "acting in concert", and therefore not at arm's length when they wind up the structure in order to sell the shares? ... XXXXXXXXXX 2005-013304 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Collectively the "Investors" Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX in which you ask for an advance income tax ruling on behalf of the above Investors. ... Yours truly, XXXXXXXXXX Acting Section Manager International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch XXXXXXXXXX ...

2005 Ruling 2005-0115381R3- XXXXXXXXXX Unedited CRA Tags 12(1)(x) Principal Issues: Whether XXXXXXXXXX who receive computers and computer training from the XXXXXXXXXX must include an amount in income under paragraph 12(1)(x). ... XXXXXXXXXX 2005-011538 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX We are writing in response to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above taxpayer, and our subsequent correspondence. ... All statutory references in this letter are to the Act, unless stated otherwise; (b) "bulletins" means XXXXXXXXXX; (c) "Canco" means XXXXXXXXXX described in Paragraph 2; (d) " Corporate Act " means the XXXXXXXXXX; (e) "CRA" means the Canada Revenue Agency; (f) "Emergency" means a XXXXXXXXXX; (g) "Entity" means the XXXXXXXXXX; (h) "e-strategy" means the Entity's XXXXXXXXXX strategy; (i) "Official" means the XXXXXXXXXX; (j) "Paragraph" means a numbered paragraph in this advance income tax ruling; (k) "Participants" means XXXXXXXXXX; (l) "Persons" means XXXXXXXXXX; (m) "Policy Objective" means the Entity's policy objective of improving XXXXXXXXXX; (n) "Proposed Transactions" means the transactions described in Paragraphs 4 to 13; (o) "Province" means the Province of XXXXXXXXXX; (p) "Recommendations" means recommendations made XXXXXXXXXX; (q) Services" means XXXXXXXXXX services; (r) "Strategy" means the XXXXXXXXXX; and (s) "workplace" means XXXXXXXXXX. ...