Search - 微信撤回和删除的区别 官方

. … CRA went on to note: The reduction in ACB for foreign taxes paid on behalf of a partner may occur prior to the addition to the ACB for the allocation of foreign income to the partner which is made on the first day of the following fiscal period. ...

CRA has viewed a société en commandite simple in France as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

CRA has viewed a French société en commandite simple as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

In that case, the municipality is merely acting as a conduit for the other person, and it is our view that amounts received by the municipality on behalf of the other person do not qualify as gifts to a municipality …. ...

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

. … In such case, the CRA would generally rely on the relevant foreign corporate or company law and the details of the plan of conversion to determine whether there is a continuity of existence on the Conversion. ...

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

. … [I]t is our view that the First Parking Space is a component of the housing unit (i.e., the Condo). ...

However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...

. … Subsection 15(1) could apply, for example, if at the time the loan is made by Aco, the other corporation (“Bco”) is unable to repay the loan and/or provide reasonable security, with the result that the value of Aco would be impaired. ...