Search - 报销 发票日期 消费日期不一致

Since that article does not define the term "gain" for purposes of the Convention, it is necessary to follow the provisions of paragraph 2 of Article III which states that "... any term not defined therein shall, unless the context otherwise requires and subject to the provisions of Article XXVI (Mutual Agreement Procedure), have the meaning which it has under the law of that State concerning taxes to which the Convention applies". ... We trust this is adequate for your purposes. for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch APPENDIX A Proceeds (April 30, 1989) $150,000 Cost $ 50,000 V-Day Value $ 80,000 Outlays and Expenses $ 10,000 # of months property owned after December 31, 1971 208 # of months property owned between December 31, 1971 and December 31, 1984 156 Proceeds of disposition $150,000 Less: ACB $80,000 Outlays and Expenses $10.000 90.000 Gain liable to tax $ 60.000 Taxable Capital Gain (115(1)(b)) $60,000 X 2/3 $ 40.000 Exempt Portion of Gain (Article XIII(9)) $60,000 X 156/208 $ 45.000 Deduction from Income (115(1)(d) and 110(1)(f)) $45,000 X 2/3 $ 30.000 ...

14 November 1989 Income Tax Severed Letter AC4131G1B F- Canada-Germany Social Security Agreement Unedited CRA Tags n/a 19(1) 19(1)   A. Watson   (613) 957-2072   HBW 4131-G1 November 14, 1989 Dear 19(1) Re: 19(1) This is in answer to your letter, dated September 21, 1989 in which you request our concurrence in special arrangements under Article 10 of the Agreement on Social Security between Canada and the Federal Republic of Germany. ... Savage A/Director Provincial and International Relations Division c.c.       ...

20 June 1990 Income Tax Severed Letter HBW4131G1B F- Canada-Germany Social Security Agreement Unedited CRA Tags n/a 19(1) 19(1)   HBW 4131-G1   A. Watson   (613) 957-2072 June 20, 1990 Dear 19(1) Re: 19(1) This is in answer to your letter, dated May 10, 1990, in which you request our concurrence in special arrangements under Article X of the Agreement on Social Security between Canada and the Federal Republic of Germany. ... Yours sincerely, Christine SavageActing DirectorProvincial and International Relations division c.c.      ...

5 December 1989 Income Tax Severed Letter ACC8951 F- Availability of Information Unedited CRA Tags n/a   19(1) 89M12402   E.E. Campbell   (613) 957-2067 December 5, 1989 Dear 19(1) Re:  19(1) On April 13, 1989, we wrote to the Deputy Minister of Finance asking for information on the above noted.  ... Special Investigations (A & Q) EEC/sg19(1)File copySequence file Author's copyChrono file (2)Reading file ...

Senécal   (613) 957-2074   HBW 8800-2   HBW 1046-6 October 23, 1989 Gentlemen: This is in reply to your letter of September 26, 1989, requesting our opinion as to whether the "Order Respecting the Remission of Income Tax in Respect of Certain Income of Individuals Earned in the Province of Quebec (1988)" (the "Remission Order") would apply to a non-resident trust. ...

4 May 1989 Income Tax Severed Letter 57814 F- Resource Expense of Limited Partnership Unedited CRA Tags 66.8(2)   95-7814 Current Amendments &                    Rulings Directorate   Regulations Division                  Resource Industries                                          Section B. ...

RESPONSE R & D quality of audits have always been a district office responsibility.  Consistency of application of R & D audit policies from district to district is ensured by Head Office through:     i)   Development and communication of audit policies and procedures;     ii)  staff training;     iii) technical support and assistance. The responsibility for resolution of whether something qualifies as R & D will remain with the R & D advisor in Ottawa. ...

It states:      A treaty shall be interpreted in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose... ... SavageA/DirectorProvincial and International Relations Division b.c.c.      Jacques Sasseville Department of Finance      Michele TrottierFinancial Industries Division BF/sgno 2 98File copySequence file ...

. $ 50 $ 250 F.M.V. $ 500 $ 2,500 2. (a) Mr. B.deals at arm's length with Mr. ... The parties elect to have the provisions of subsection 85(1) of the Act apply to the transfer and agree to the following: Amount elected under subsection 85(1) $ 50 Fair market value of shares 500 Paid-up capital of shares issued by C Co. 50 (b) Step 2 A Co. transfers the $500 asset to C Co. in exchange for 500 redeemable, retractable preferred shares in C Co. ... It is also your opinion that the reference to "... a disposition at fair market value of any share of capital stock immediately before the dividend... ...

8 November 1989 Income Tax Severed Letter ACC8489 F- Limited Partnership At-Risk Rules Unedited CRA Tags 96(2.2)96(2.2)(d)   89M12526   November 8, 1989 To: Review Committee Resource Industries Section   Allan B. Nelson   957-8984   Subject: Limited Parnter At-risk Rules Paragraph 96(2.2) of the Act Purpose We are writing to request your direction concerning the possible application of paragraph 96(2.2)(d) of the Act in a fact situation on which we have been asked to provide an advance income tax ruling. ...