Search - 广东省2005政府工作报告 一小发展 金句

2005 Ruling 2004-0101581R3- Safe income extraction Unedited CRA Tags 55(2) 88(1)(c) Principal Issues: The availability of the bump on a safe income extraction. ... XXXXXXXXXX 2004-010158 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX (hereinafter referred to as "Holdco") XXXXXXXXXX (hereinafter referred to as "Aco1") XXXXXXXXXX (hereinafter referred to as "Newco1") XXXXXXXXXX (hereinafter referred to as "Newco2") XXXXXXXXXX (hereinafter referred to as "Aco2") XXXXXXXXXX (hereinafter referred to as "Newco3") XXXXXXXXXX (hereinafter referred to as "Newco4") XXXXXXXXXX (hereinafter referred to as "Shco") XXXXXXXXXX XXXXXXXXXX (hereinafter referred to as "Jco") XXXXXXXXXX (hereinafter referred to as "Lco") This is in reply to your letter of XXXXXXXXXX, and your E-mails of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayers. ... The amount to be added to the stated capital of the Newco4 class A common shares so issued will be an amount equal to the aggregate adjusted cost base of the common shares of Pubco so transferred (the "Transferred Shares "4 ""). 15. ...

Reasons: Based upon the facts of the situation and a written opinion received from Natural Resources Canada dated October 14, 2005. ... XXXXXXXXXX 2005-014322 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX. ... On XXXXXXXXXX, 2005, a favourable advance income tax ruling (our file # 2004-010307) was issued concerning expenses qualifying under paragraph (f) of the definition of CEE related to proposed exploration drilling programs to be undertaken on three other zones on the Property. ...

2005 Ruling 2005-0139621R3- 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 Position: Acceptable Reasons: Paragraph 32 of IT-533 XXXXXXXXXX 2005-013962 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX ("A Co") XXXXXXXXXX ("B Co") XXXXXXXXXX ("C Co") This is in reply to your letter of XXXXXXXXXX, wherein you request an advance income tax ruling on behalf of the above named taxpayers. ... Quarterly, C Co will pay a dividend of $XXXXXXXXXX ($XXXXXXXXXX ÷ XXXXXXXXXX) to B Co. ...

2005 Ruling 2005-0140221R3- 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 2005-014022 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2005-0149491R3- Shareholder Loan and Deemed Interest Income Unedited CRA Tags 17(1) 17(2) Principal Issues: 1. ... XXXXXXXXXX 2005-014949 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Advance Income Tax Ruling This is in response to your XXXXXXXXXX request for an advance income tax ruling on behalf of the above taxpayers. ... Yours truly, XXXXXXXXXX for Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

2005 Ruling 2005-0149751R3- Reorganization of a business Unedited CRA Tags 84(2) 84(4.1) Principal Issues: Transfer of some operations which are highly integrated to the taxpayer's business and of the assets required for those operations to a third party. ... XXXXXXXXXX 2005-014975 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling We are writing in response to your letter of XXXXXXXXXX wherein you requested an advance income tax ruling on behalf of the above-referenced taxpayers. ... Those services are rendered on a cost recovery basis plus XXXXXXXXXX %. ...

2005 Ruling 2004-0096311R3- Deferred Share Units- Bonus Plan Unedited CRA Tags 248(1) 5(1) Principal Issues: Whether a plan that provides for the payment of a bonus based on the value of restricted stock units credited to a participant is excluded from the SDA definition by virtue of the exception in (k) of that definition? ... XXXXXXXXXX 2004-009631 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request XXXXXXXXXX ("Pubco") This is in reply to your letters of XXXXXXXXXX and electronic correspondence of XXXXXXXXXX wherein you request an advance income tax ruling on behalf of the above-noted taxpayer. ... If Annual Individual Goals and Annual Corporate Goals are only partially attained, the Participant may be entitled to receive a pro-rata portion of the Performance Vesting RSUs, the number of which will be determined at the discretion of the CEO or the Chair of the Board, as the case may be. e) No Participant shall be entitled to any benefit in respect of RSUs granted under the Plan to the extent that such RSUs have not vested in favour of the Participant. f) Subject to subparagraph 8(o) below, any RSUs applicable to a particular Grant to which a Participant does not become entitled under the Time Vesting Criteria, the Annual Corporate Goals or the Annual Individual Goals shall be forfeited immediately upon such determination. g) Upon the vesting of RSUs under the Plan, Pubco will determine the amount that is payable to a Participant based on the following formula: (Vested RSUs x Average Market Price on the Entitlement Date)- Tax Withholding = funds payable to the Participant h) The amount payable to the Participant (based upon the formula in subparagraph (g) above) will be paid to the Participant in cash. i) Pubco will pay amounts owing under the Plan to the Participant each year in which a Participant's RSUs vest. ...

2005 Ruling 2004-0093711R3- Incorporating a Proprietorship Unedited CRA Tags 125(7) 56(2) & (4) Principal Issues: Whether a physician who is also a faculty member of a university can conduct a medical practice through a corporation. ... XXXXXXXXXX 2004-009371 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX This is in reply to your letter dated XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above. ...

2005 Ruling 2004-0055911R3- Withholding tax on interest; Part XIII Unedited CRA Tags 212(1)(b)(iii)(E) Principal Issues: 1. ... Position: Yes / yes Reasons: XXXXXXXXXX- 1. "Obligation" is a broad term 2. ... XXXXXXXXXX 2004-005591 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling XXXXXXXXXX This is in reply to your letters of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the above-noted taxpayer, with respect to whether certain amounts paid by the taxpayer to non-resident XXXXXXXXXX would be exempt from withholding tax under Part XIII of the Income Tax Act (the "Act") pursuant to clause 212(1)(b)(iii)(E) of the Act. ...

2005 Ruling 2005-0126651R3- Trust Variation- Redemption Rights Unedited CRA Tags 108(2) 132(6) Principal Issues: Whether the variation of trust to provide for redemption rights and for the creation of a special class of units which would not provide its holder with any rights as to the income and capital of the trust but would allow it to vote at meetings of the unit holders would result: (i) in a disposition by the existing unit holders of their units; (ii) in a disposition by the trust of its assets or in a resettlement of the trust; and (iii) in the trust qualifying as a "unit trust" under paragraph 108(2)(a) and a "mutual fund trust" under subsection 132(6) of the Act immediately after the variation. ... XXXXXXXXXX 2005-012665 XXXXXXXXXX, 2005 Dear XXXXXXXXXX: Re: XXXXXXXXXX Advance Income Tax Ruling Request This is in reply to your letter of XXXXXXXXXX, in which you request an Advance Income Tax Ruling on behalf of the above named taxpayer. ... Yours truly, XXXXXXXXXX Section Manager For Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...