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Technical Interpretation - External summary
16 June 2010 External T.I. 2009-0344861E5 F - Actifs de la Catégorie 16 -- summary under Paragraph 16(e)
. … Subparagraph (e)(ii) of the definition of automobile refers to pick-up trucks and/or vans the use of which, in the taxation year in which they are acquired or leased, are all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income. ...
Technical Interpretation - External summary
11 June 2010 External T.I. 2010-0354881E5 F - Traitement fiscal de la FNACC -- summary under Subsection 20(16)
. … …[T]o the extent that the CFVP was the only depreciable property included in Class 10, the change in use of the CFVP results in no property being included in Class 10. ...
Technical Interpretation - Internal summary
30 September 2010 Internal T.I. 2010-0373901I7 F - Bigamie fiscale - transfert de biens au décès -- summary under Subparagraph 40(4)(b)(i)
30 September 2010 Internal T.I. 2010-0373901I7 F- Bigamie fiscale- transfert de biens au décès-- summary under Subparagraph 40(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(4)- Paragraph 40(4)(b)- Subparagraph 40(4)(b)(i) application of s. 40(4)(b)(i) by both surviving spouse re House A and surviving common-law partner re House B – but not for overlapping years The taxpayer lived with his spouse in Immovables A, but thereafter commenced to live separate and apart from her, but did not divorce from her, and instead lived in a conjugal relationship with another (a common-law partner) in Immovable B until his death. ...
Conference summary
8 October 2010 Roundtable, 2010-0373251C6 F - Immeuble détenu par une société -- summary under Subsection 15(1)
. … The following are some elements that may be considered by the CRA in determining the "normal rate of return" in a particular situation: The rate of return that the corporation could earn on the capital invested to acquire the property made available to its shareholder; The rate of interest on a loan that the shareholder would have received from a person with whom the shareholder deals at arm's length if the shareholder had borrowed personally to acquire the property made available to the shareholder. ...
Conference summary
8 October 2010 Roundtable, 2010-0373351C6 F - Évaluation d'une clause restrictive -- summary under Subsection 56.4(2)
. … [K]eeping in mind that what is being valued are conditions of a sale that are essential to the closing of the sale, the various elements that would have an impact on the income of the business sold must be evaluated in light of each individual situation. ...
Technical Interpretation - External summary
4 May 2010 External T.I. 2009-0329391E5 F - Provision pour retour de marchandises -- summary under Paragraph 18(1)(e)
After indicating that no reserve under s. 20(1)(m) was available, and confirming its position in IT-215R, para. 13, CRA stated: [A] clause permitting the return of goods not sold by customers is not a clause contemplated by paragraph 13 … where title passes to the purchaser upon delivery, well before the expiry of the time limit for the return of goods. ...
Conference summary
8 October 2010 Roundtable, 2010-0373311C6 F - Oeuvres d'artistes étrangers -- summary under Listed Personal Property
We are of the view that a painting by a foreign artist that is owned by a public corporation and used exclusively to decorate a boardroom of that corporation is probably not personal-use property of that corporation …. ...
Conference summary
8 October 2010 Roundtable, 2010-0373261C6 F - Choix prévu au paragraphe 184(3) -- summary under Subsection 220(3.5)
. … [A]s a matter of first impression, it cannot be assumed that a request for an extension of time under subsection 220(3.2) to file an election under subsection 184(3) would necessarily be denied in a particular situation similar to the given hypothetical situation. ...
Technical Interpretation - Internal summary
9 December 2010 Internal T.I. 2010-0371741I7 F - Automobiles mises à la disposition des employés -- summary under Automobile
In both of the situations described above, since the vehicles … are designed and constructed with more than three seating positions and are not similar to a van or pick-up truck, we are of the view- based on their use- that those vehicles are automobiles for the purposes of the Act. ...
Technical Interpretation - External summary
5 November 2010 External T.I. 2010-0383871E5 F - Crédit d'impôt pour emploi à l'étranger -- summary under Paragraph 122.3(1)(b)
. … For example, if the qualifying period is 14 continuous months, and assuming that the employment duties are performed consistently over the period, the employee would not normally be expected to spend more than 1.4 months (10% of 14) in Canada performing the duties of employment that would otherwise qualify for the OETC. ...