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Technical Interpretation - Internal

12 August 2010 Internal T.I. 2009-0328671I7 - Deduction pursuant to paragraph 20(1)(e)

The relevant facts can generally be summarized as follows: In XXXXXXXXXX, XXXXXXXXXX and its subsidiaries ("XXXXXXXXXX ") applied for and received protection under the CCAA. ...
Technical Interpretation - Internal

20 January 2010 Internal T.I. 2009-0348571I7 - Interest Rate Swaps and Resource Profits

The Queen 99 DTC 5669 [SCC] and Stewart v The Queen 2002 DTC 6969 "XXXXXXXXXX " However, we have been unable to identify any comments in either of these decisions that support the Representative's position. ...
Technical Interpretation - Internal

19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE

In the Macmillan-Bloedel decision, the judge stated: "... when one carefully analyzes the situation, there are, from a business and accounting view, two transactions. ...
Technical Interpretation - Internal

18 December 2012 Internal T.I. 2012-0461651I7 - Foreign Tax Credits - s. 126 vs. s. 110.5

The transactions must also be in full technical compliance with relevant provisions of the Act, including paragraph 20(1)(c) where interest expense deductions are claimed and subsections 112(1) – (2.4) if relying on inter-corporate dividend deductions. ...
Technical Interpretation - Internal

6 May 2014 Internal T.I. 2014-0524651I7 - Loss on conversion

$XXXXXXXXXX ÷ U.S.$XXXXXXXXXX) would have been issued. This differential likely indicates that the conversion did not occur pursuant to the terms of the Notes. ...
Technical Interpretation - Internal

14 February 2014 Internal T.I. 2013-0490891I7 - Revocable Living Trust

In the event the trust is revoked under this Section XXXXXXXXXX, the Trustee shall forthwith distribute the entire then trust estate of the trust in the following shares – XXXXXXXXXX to Mother and XXXXXXXXXX each to the Children. ...
Technical Interpretation - Internal

8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares

Generally, in files where the status of XXXXXXXXXX MRPS as equity as opposed to debt or some other type of instrument- was relevant, Rulings accepted that such MRPS would be treated as equity for purposes of the Act. ...
Technical Interpretation - Internal

20 September 2002 Internal T.I. 2002-0146627 - Statute barred limits, Section 216S. 216; S. 152(8)

September 20, 2002 International Policy & Business HEADQUARTERS Management Division Income Tax Rulings Directorate Policy and Publications Unit I S. ...
Technical Interpretation - Internal

16 April 2012 Internal T.I. 2011-0404271I7 - Restitution of property looted during WWII

The Queen, 2009 TCC 293 as follows: Cranswick must be read in light of the fact that the trial judge's statement that the payment was not made by reason of any enforceable claim asserted by the shareholders of the Canadian subsidiary results from a specific statement to that effect contained in an agreed statement of facts. ...
Technical Interpretation - Internal

28 July 2011 Internal T.I. 2011-0394981I7 - Cooperative Housing and 149(1)(l)

C.35: Subsection 55(1) "... [T]he surplus arising from the business of a co-operative... in each fiscal year shall be allocated, credited or paid to the members in proportion to the business done by each member with or through the co-operative... ...

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