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Technical Interpretation - Internal

23 October 2002 Internal T.I. 2002-0135797 - FOREIGN EXCHANGE LOSSES

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal

31 October 2002 Internal T.I. 2002-0142497 - FOREIGN EXCHANGE LOSSES

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal

27 November 2002 Internal T.I. 2002-0140507 - FOREIGN EXCHANGE LOSS

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal

27 November 2002 Internal T.I. 2002-0140517 - FOREIGN EXCHANGE LOSS

In document # 9703377, we indicated that "for purposes of paragraph 20(1)(f) the principal amount under the terms of the CBL (Consumer Based Loan) is the total amount paid on maturity plus the total of all payments in satisfaction of principal paid over the life of the obligation. ...
Technical Interpretation - Internal

25 February 2003 Internal T.I. 2003-0001677 - DEMUTUALIZATION CONVERSION BENEFIT

February 25, 2003 XXXXXXXXXX TSO HEADQUARTERS Business Enquiries Financial Institutions Section Verification & Enforcement Division Income Tax Rulings Directorate Attention: XXXXXXXXXX Alison Campbell (613) 957-3496 2003-000167 Demutualization Payments to Employees We are replying to your request for assistance in determining the appropriate application of section 139.1 of the Income Tax Act, in respect of a particular taxpayer. ...
Technical Interpretation - Internal

25 January 2000 Internal T.I. 1999-0006847 - REQUEST RECEIVED BY NPO

We trust that our comments will be of assistance to you. for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...
Technical Interpretation - Internal

16 June 2000 Internal T.I. 1999-9914177 - REFUNDABLE INVESTMENT TAX CREDITS

The Band Council only owned XXXXXXXXXX % of the shares. De facto control of the corporation was not with a person exempt from tax under section 149. ...
Technical Interpretation - Internal

26 May 2000 Internal T.I. 2000-0025790 - ALLOCATION TRANSFER PROGRAM-STATUS INDIAN

Department of Fisheries & Oceans Allocation Transfer Program Questions and Answers For Canada Customs and Revenue Agency Client Services The Department of Fisheries and Oceans ("DFO") is responsible for issuing fishing licences which include commercial fishing licences to the public. ...
Technical Interpretation - Internal

25 June 1999 Internal T.I. 9905707 - RESOURCE ALLOWANCE

Robert Parsons stated: if the producer should choose to close out the forward sales contract earlier than it was required to do, by purchasing an equivalent amount of product, this action does not alter the characterization of the gain or loss on the forward sales contract as a hedging transaction. ...
Technical Interpretation - Internal

18 February 2022 Internal T.I. 2020-0836351I7 - 212(1)(d)/Copyrights/Trademarks/XXXXXXXXXX

., XXXXXXXXXX% copyrights and XXXXXXXXXX % trademarks). In general, where a contract provides for a payment subject to tax under paragraph 212(1)(d) and for a payment that is not otherwise subject to part XIII tax under the Act, the onus is on the CRA to determine which portion of the payment is subject to tax. ...

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