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Technical Interpretation - Internal

21 October 1998 Internal T.I. E9823767 - CHILD SUPPORT PAYMENTS

See file # 9801315. The tax consequence of an amount received does not arise merely because a court order has so stipulated. ...
Technical Interpretation - Internal

15 May 1997 Internal T.I. 9635617 - TRANSFER OF SHARES OF AN NPO HELD IN TRUST

While the declaration indicates that a member holds the share certificate in trust for the Organization and that the member has no beneficial ownership in the share, the declaration then specifies that the member has transferred the said share certificate in blank, " XXXXXXXXXX" In this respect, the representative further indicates that "the Share Certificate is transferred in blank in favor of the company. ...
Technical Interpretation - Internal

18 June 1997 Internal T.I. 9703926 - RPP CPP LUMP SUM PYMT RIGHT OR THING

The IT states that where this occurs, "... the portion of the lump-sum payment which would have been taxable had it been received by the decedent normally is still regarded as income of the estate or the beneficiary; but if the executor desires, for any reason, to report that amount as income of the employee for the year of death pursuant to subsection 70(2), no objection will be made to that manner of reporting nor any consequential election properly made under 70(2). ...
Technical Interpretation - Internal

15 October 1997 Internal T.I. 9638486 - MODIFIED CO-INSURANCE

The following reserve change would occur: Opening reserves 1,000,000 Plus interest income 100,000 Less claims (263,798) Closing reserves 836,202 Reserve change 1,000,000- 836,202 = 163,798 (decrease) Since the reinsurer is responsible for 90% of reserves, 90% of the decrease in reserves or $147,418 must be credited to the reinsurer. ...
Technical Interpretation - Internal

4 December 1997 Internal T.I. 9728097 F - APPLICATION DE LA LOI

Plus précisément, l'alinéa 67.1(2)c) de la Loi prévoit que: " Le paragraphe 1 ne s'applique pas au montant payé ou payable par une personne pour des aliments, des boissons ou des divertissements dans les cas suivants:... c) le montant est payé ou payable contre un paiement raisonnable indiqué de façon précise par écrit à la personne qui fait ce paiement. ...
Technical Interpretation - Internal

15 May 1998 Internal T.I. 9719587 - CAPITAL GAINS DEDUCTION ON 72(2)(C) RESERVE

XXXXXXXXXX RECOMMENDATION XXXXXXXXXX We trust the foregoing comments assist. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...
Technical Interpretation - Internal

5 May 1998 Internal T.I. 9808496 - CAPITALIZATION OF INTEREST (COST PER PUPIL)

If you have any questions concerning this matter please feel free to contact us. for Director Financial Industries Division Income Tax Rulings & Interpretations Directorate Policy and Legislation Branch ...
Technical Interpretation - Internal

13 October 1998 Internal T.I. 9821607 - COMPUTATION OF LOAN LOSS RESERVES

Lee Workman Manager Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...
Technical Interpretation - Internal

5 November 1998 Internal T.I. 9806237 - ALLOWABLE BUSINESS INVESTMENT LOSSES

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch??... ...
Technical Interpretation - Internal

21 October 1998 Internal T.I. 9823767 - CHILD SUPPORT PAYMENTS

See file # 9801315. The tax consequence of an amount received does not arise merely because a court order has so stipulated. ...

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