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Ruling summary
2014 Ruling 2013-0514561R3 - Payment in lieu of continued PHSP coverage -- summary under Paragraph 6(1)(a)
Proposed transactions Former employees (and dependants where relevant) will receive under a CCAA Plan one or more payments out of the available cash pool of Canco on account of their claim for termination of coverage under the Plans in an amount equal to their pro-rata share of the aggregate settlement amount – except that claims under a Life insurance plan will be paid separately. ...
Technical Interpretation - Internal summary
13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices -- summary under Subparagraph 6(1)(a)(i)
. … Since a portion of the lump sum received in respect of the Medical Plan was received before 2012, that portion does not have to be included in the computation of the Objectors’ income. ...
Technical Interpretation - Internal summary
23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization -- summary under Paragraph 149(1)(l)
" … [A] member of a non-profit organization can make a loan to a NPO without jeopardizing the status of the NPO, even if the member, as a creditor, receives interest on its debt to the extent that the interest rate on its claim is reasonable. ...
Technical Interpretation - Internal summary
21 January 2013 Internal T.I. 2012-0442021I7 F - Assessing 163(2) penalty -- summary under Subparagraph 163(2)(a)(i)
. … If, on the other hand, the CCA relates more to the business as a whole (i.e. related to reported income and undeclared income), we are of the view that it would not be wholly applicable to undeclared income and would not be allowed as a deduction for the purpose of calculating the penalty. ...
Ruling summary
2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation -- summary under Paragraph 149.1(2)(a)
. … [T]he Charities Directorate…have advised us that… the performance of XX services by the Charity to Newco would be a business that is not a related business. ...
Technical Interpretation - External summary
30 April 2013 External T.I. 2013-0475271E5 F - CCTB - Marital Status Change -- summary under Paragraph 122.62(7)(b)
. … Mr. B's income will not be considered in setting the CCTB for the months before July 2012 since paragraph 122.62(7) (b) applies only to a month that begins after a change in marital status. ...
Technical Interpretation - External summary
21 August 2014 External T.I. 2014-0527611E5 - T1135 for Deceased Individual -- summary under Subsection 233.3(3)
This combined value should be included in Category 6 of Form T1135, " Other property outside of Canada. ...
Technical Interpretation - External summary
25 August 2015 External T.I. 2015-0571271E5 F - Affiliated Trusts under Paragraph 251.1(1)(h) -- summary under Contributor
X would also, by virtue of subparagraph 251.1(4)(d)(i), be a majority interest beneficiary of Trust B… … Trust A and Trust B would thus be affiliated…by virtue of subparagraph 251.1(1)(h)(i)…. ...
Ruling summary
2015 Ruling 2014-0559181R3 - Internal Reorganization -- summary under Paragraph 55(3)(a)
. … [or that the] Proposed Transactions… will have any material impact on the trading price of the shares of the capital stock of Ultimate Parentco or the value of the options held by the Optionholders. ...
Technical Interpretation - External summary
11 March 2013 External T.I. 2012-0469231E5 F - Deferred terminal loss -- summary under Paragraph 13(21.1)(a)
CRA responded: [T]he elements applied to determine the proceeds of disposition of the building according to the calculation rules set out in paragraph 13(21.1)(a) … are, inter alia, the fair market value of the land immediately before its disposition and its cost amount to the vendor. ...