Search - 教職 奨学金免除
Results 771 - 780 of 791 for 教職 奨学金免除
Technical Interpretation - Internal summary
22 July 2008 Internal T.I. 2008-0284351I7 - Subsection 20(12) -- summary under Subsection 20(12)
. … [I]n... Kaiser... 91 DTC 1057...the taxpayer tried [unsuccessfully] to convince the Tax Court that foreign taxes paid on employment income were deductible under subsection 20(12).... ...
Technical Interpretation - Internal summary
22 June 2015 Internal T.I. 2014-0553731I7 - Deduction of Terminal Loss - Wind-up -- summary under Subsection 1102(14)
. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...
Technical Interpretation - Internal summary
29 July 2015 Internal T.I. 2015-0575921I7 - Recapture arising in statute-barred years -- summary under Subsection 13(1)
. … If the total of all the decreases exceeds the total of all the increases to the UCC of a class as of the end of a taxation year, subsection 13(1) provides that this excess shall be included in computing the taxpayer's income for the year. ...
Technical Interpretation - Internal summary
14 March 2014 Internal T.I. 2013-0499141I7 - IRC 338(h)(10), "earnings" and safe income -- summary under Paragraph 5907(2)(f)
(a)(i) of the "earnings" definition) – without duplication of the adjustments in 1 and 2. ...
Technical Interpretation - Internal summary
10 September 2013 Internal T.I. 2010-0387631I7 - Surplus accounts; Disposition of foreign affiliate -- summary under Subsection 5902(1)
" This could be the case given that the payment of the dividends may have fully accessed any available exempt surplus of CCo, whereas if there instead had been a sale of CCo shares to NR1 at a gain followed by a s. 93(1) election, the amount of exempt surplus which was accessed under the operation of Regs. 5902(1) and 5901 could be more limited – which would result in pre-acquisition surplus dividends grinding basis under s. 92(2) which, in turn, would result in a taxable capital gain which was foreign accrual property income. ...
Technical Interpretation - Internal summary
15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement -- summary under Paragraph 6(1)(a)
. … If it is instead established on the facts that the taxpayer did not ordinarily reside at Location 2 before ordinarily residing at Location 3…[e]xpenses related to the sale of the residence at Location 1 would be considered expenses of the move from Location 1 to Location 3…. ...
Technical Interpretation - Internal summary
7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Subsection 152(4)
…[T]he CRA should not accept the adjustment request … as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...
Technical Interpretation - Internal summary
26 January 2018 Internal T.I. 2017-0735771I7 - Application of paragraph 40(3.5)(c) -- summary under Paragraph 40(3.5)(b)
. … Above, it was noted that transactions that fall within sections 51, 86, 87 or 85.1 are carved out of a “merger” in subparagraph 40(3.5)(c)(i). ...
Technical Interpretation - Internal summary
12 May 2004 Internal T.I. 2004-0061071I7 F - Assistance sociale - Famille d'accueil -- summary under Paragraph 81(1)(h)
For the purposes of subparagraph 81(1)(h)(i), we are of the view that the children's special allowance [so] paid … is not an amount of family allowance under the LAF and the payment of such an allowance would not preclude the exemption from the social assistance benefit that would otherwise qualify pursuant to paragraph 81(1)(h). ...
Technical Interpretation - Internal summary
6 February 2019 Internal T.I. 2018-0762101I7 - Ruling request - DSU plan and EPSP -- summary under Paragraph 6801(d)
The EPSP trust would use an interest-bearing loan from Employerco to fund its purchase of the matching number of Employerco shares and fund the loan interest with dividends on the shares and annual contributions from Employerco – both of which were taxable income to it but with an offsetting interest deduction, so that there would be no annual income inclusion to the participant under s. 144(3). ...